Cost Sharing Groups

In the conclusions to the case C-275/15 European Commission vs. Luxembourg, Advocate General Kokott gives very little chance to the VAT exemption of cost sharing groups (“CSG”, “groupements autonomes de personnes or GAP”) to live on, at least in its current wording. This will obviously affect a large number of financial institutions based in Luxembourg and it is the right time for them to revisit the arrangements in place. If the Commission did only address the case of Luxembourg, it will however necessarily have an impact on the VAT legislation and practice of the other European countries that apply the exemption in similar terms, such as in France, Belgium or in the UK.