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Ryanair: holding companies recovering VAT

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Ryanair was planning to acquire Aer Lingus. Its intention was to provide management services to the other airline after the takeover. However, its bid was unsuccessful. It is settled law that VAT incurred for the purposes of management services supplied by a holding company to its subsidiaries is (in principle) deductible, just as it is settled law that VAT incurred for the purposes of intended economic activities that abort is also (in principle) deductible. The recent CJEU ruling in Ryanair (Case C-249/17) demonstrates how these two sets of principles interact.

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