Germany MOF Clarifies Input VAT Deductions for Subsidized Service Providers Operating at Persistent Loss

Jan. 26, 2026, 5:00 AM UTC

The German Ministry of Finance Jan. 20 posted BMF Letter No. COO.7005.100.4.13831037, clarifying input VAT deductions for service providers operating at a persistent loss while receiving public subsidies. Topics covered include: 1) the lack of entitlement for such service providers operating at a persistent loss to deduct input VAT when the input services are unrelated to taxable activity; 2) the two-step test to establish whether such service providers are eligible for input VAT deductions, including determining if there is a direct link between remuneration and performance, and the existence of economic activity; 3) the amendment of the VAT Application Decree ...

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