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EU: CJEU Advocate General opinion on VAT treatment of credit management in securitization structures (Finland)

Credit management performed by originating lender after transfer of loans not VAT-exempt

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March 18, 2026

The Court of Justice for the European Union (CJEU) on February 25, 2026, published the nonbinding opinion of its Advocate General (AG) in case T-184/25 (Veronsaajien oikeudenvalvontayksikkö v. A Oy) concerning the value added tax (VAT) treatment of credit management in securitization structures.

The AG concluded that credit management performed by an originating lender after transferring the loans does not fall within the VAT exemptions in article 135(1)(b), (c), or (d) of Council Directive 2006/112/EC.

According to the AG, once the credit is transferred, post‑transfer servicing constitutes an independent supply of services to the purchaser and would therefore be subject to VAT.

The AG proposed that exempt treatment be limited to services forming part of the ongoing credit relationship, to preserve VAT neutrality and prevent avoidance.


For more information, contact a KPMG tax professional in Finland:

Lassi Ahopelto | lassi.ahopelto@kpmg.fi

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