On 13 December 2017, the French Administrative Supreme Court (Conseil d’Etat) issued a new decision according to which the rebilling, without markup, by a mix holding, of advisory costs incurred in the frame of acquisition of shares performed by its subsidiaries, qualifies an occasional activity subject to VAT under the standard conditions.
Indeed, such rebilling is made by a taxpayer carrying out a taxable activity on a permanent basis. Hence, the turnover generated by such rebilling should be included in the two terms of the input VAT recovery ratio.
