Exemptions for other activities EU VAT case law

3 cases of the Court of Justice and the General Court of the European Union on this point of VAT law, from 2019 to 2025.

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Article 135 of Directive 2006/112/EC Exemptions for other activities · 3 of these cases

The 3 cases, most recent first

Under each case, what the Court decided, from its summary. The summaries are AI-generated and are not official documents: open the case for the Court’s own text.

T-657/24 Versãofast

Judgment · 26 November 2025 · Portugal

Scope of the exemption for negotiation of credit

The exemption applies. Services which, taken as a whole, do all that is necessary for the credit institution to conclude loan agreements with potential customers amount to negotiation of credit, even where individual elements (handing over brochures, receiving replies) would in isolation be mere administrative acts. Neither the absence of authority to act in the bank's name, nor the lack of influence over pre-set terms, nor the customer's freedom of choice prevents exemption. Remuneration tied to loans actually concluded supports that purpose. The overall assessment is for the referring court. Confirms that intermediation exemption turns on the purpose of the package of services, not on contractual authority or on the ability to negotiate terms. Relevant to mortgage and consumer credit brokers, tied agents, estate agency and comparison networks, and lead generators paid on completion.

C-89/23 Companhia União de Crédito Popular

Judgment · 18 April 2024 · Portugal

Auction of pledged goods as a supply separate from exempt pawnbroking

The Court held that the auction organisation services are not ancillary to the granting of pledge-secured credit and do not share its VAT treatment. They are substantively and procedurally independent, the credit could be supplied identically if a third party ran the auction, the sale is not the usual outcome of the loan but follows only from default, and it is an end in itself. Final factual assessment remains for the national court. Pawnbrokers and other lenders realising security must treat enforcement fees and sale commissions as separate taxable supplies, not as part of exempt credit, even where national law obliges the lender to conduct the sale and fixes the commission rate.

C-235/18 Vega International Car Transport and Logistic

Judgment · 15 May 2019 · Poland

Fuel cards as an exempt grant of credit

No supply of fuel took place at the parent's level. The subsidiary chose the station, quality, quantity, type and timing, bore the full cost, and so disposed of the fuel as owner. The parent merely supplied an instrument for purchasing fuel, acting as intermediary. That supply of services, remunerated by the 2% surcharge, amounts to advance financing akin to the granting of credit and is exempt under Article 135(1)(b). The exemption depends on the nature of the service, not the supplier's status. Card issuers and intra-group fuel card programmes cannot assume a buy/sell chain.