Almost 20 years on from the CJEU’s decision in Cibo Participations C-16/00 the VAT deductibility rules for holding companies continue to be one of the most fertile areas for tax litigation. Despite the jurisprudence at EU level, there is still a reluctance of tax authorities to fully accept what the courts have said, and this continues to lead to disputes with taxpayers. There remains a multitude of case law on the matter, including, from an Irish perspective, the notable 2018 Court of Justice of the European Union (CJEU) judgment in Ryanair C-249/17.
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