EDM : new guidance from Luxembourg

With its judgment of 29 April 2004 in the EDM case, the ECJ has sheds a new light on various VAT aspects of "active" holding companies, i.e. holding companies actively involved in the management of their subsidiaries. In this article, the author examines several new principles applicable to European VAT, in particular with respect to the granting of loans, deduction of VAT in respect of expenses relating to activities outside the scope of VAT, and the criteria under which exempt transactions must be excluded from the pro rata