European Court of Justice Issues Advocate General Opinion on Danish VAT Group Rules

April 28, 2026, 5:00 AM UTC

The European Court of Justice (ECJ) April 22 issued an Advocate General opinion for Case No. T-268/25, on Danish VAT group rules. The taxpayer, a Danish insurance company whose services included VAT-exempt services, sought VAT group registration with its management company, in which it held 94 percent ownership. The Danish tax authorities rejected group registration based on a national law requiring 100 percent ownership for taxable persons engaged in VAT-exempt or non-economic activities. Upon request for a preliminary ruling, the Advocate General opined that EU Directive 2006/112 on the common system of VAT, must be interpreted as not precluding EU ...

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