General Court (Fifth Chamber, sitting with five Judges) 9 September 2026, T-366/25 (D.B. v Dyrektor Krajowej Informacji Skarbowej.)
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Article 19 of Directive 2006/112/EC does not apply where an undertaking is donated in equal half shares to two natural persons, each of whom cannot independently carry on the undertaking’s economic activity. The intended immediate contribution of those shares to a general partnership owned by the recipients does not render the distinct transactions a single transfer of a totality of assets or part thereof.AI
European Union · · · 09-09-2026
Provisional text JUDGMENT OF THE GENERAL COURT (Fifth Chamber, sitting with five Judges) 9 September 2026 (*) ( Reference for a preliminary ruling – Taxation – Common system of VAT – Transfer of a totality of assets or part thereof – Article 19 of Directive 2006/112/EC – Donation of an undertaking in two equal shares to two individuals – Subsequent transfer of the shares to a general partnership
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