VAT and EU law

VAT on intra-group transactions: the scope of the single taxable person regime according to the CJEU (Case C-184/23)

Expansión and the Spanish-German legal portal LEX · February–March 2025

A case note on the Court of Justice of the European Union’s interpretation of intra-group VAT, focusing on the single taxable person regime and its implications for public bodies, corporate groups and operators carrying out partially exempt activities.

The analysis addresses the limits on Member States’ power to tax internal transactions once a VAT group has been constituted.

Sources

  • CJEU judgment of 11 July 2024, Case C-184/23.
  • Council Directive 2006/112/EC on the common system of VAT.

How to cite this work

DÍAZ-HEREDERO LÓPEZ, G., “VAT on intra-group transactions: the scope of the single taxable person regime according to the CJEU (Case C-184/23)”, DÍAZ-HEREDERO Legal & Tax, 2025. Available at: https://diazheredero-web.pages.dev/en/research/vat-intra-group-transactions-cjeu-c-184-23/ (accessed: dd/mm/aaaa).

Published content is informative in nature and does not constitute individual advice. It does not replace the analysis of a specific case or the review of the corresponding documentation.

Do you currently have a tax procedure under way? You can set out your case so that it can be assessed.

Submitting the form does not mean the matter has been accepted.

Submit an enquiry