Court of Justice (First Chamber) 23 October 2025, C-744/23 (Т.P.T. v 'Financial Bulgaria' EOOD.)

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In Case C-744/23 (Zlakov), the Court of Justice (First Chamber) addressed whether a lawyer's court representation provided free of charge to a client under Bulgarian law constitutes a supply of services for consideration under Article 2(1)(c) of the VAT Directive where, upon the client's success, the opposing party is ordered by law to pay regulated fees directly to that lawyer. The Court held that a direct link between the service and the consideration exists, established both by contract and by statute, and that the consideration being paid by a third party (the opposing party) rather than the service recipient does not negate the 'for consideration' classification, nor does the contingent nature of payment depending on the outcome of proceedings. Accordingly, Article 2(1)(c) of Directive 2006/112/EC must be interpreted as meaning that such representation constitutes a supply of services for consideration subject to VAT.AI