Opinion of the Advocate General — ECLI:EU:T:2026:141
Date: 2026-02-25
Language of the case: Finnish

Request for a preliminary ruling from the Korkein hallinto-oikeus (Finland) made on 28 February 2025 – Veronsaajien oikeudenvalvontayksikkö v A Oy (Case T-184/25, Veronsaajien oikeudenvalvontayksikkö) Language of the case: Finnish Referring court Korkein hallinto-oikeus Parties to the main proceedings Applicant: Veronsaajien oikeudenvalvontayksikkö Defendant: A Oy Questions referred Where a financial undertaking sells credit which it has granted to a customer to another financial institution and continues to manage that credit itself for consideration after having sold it, is Article 135(1)(b) of the VAT Directive, 1 which concerns the exemption from tax of the management of credit by the person granting it, to be interpreted as also covering the case where the former undertaking continues to manage the credit which it has itself granted and has sold to that other financial institution? If the answer to the first question is in the negative and the management of credit by the former undertaking concerns credit serving to secure a bond issued by another financial institution, is Article 135(1)(c) of the VAT Directive, which concerns the exemption from tax of any dealings in credit guarantees or any other security for money, to be interpreted as also covering the case where the former undertaking manages credit serving to secure a bond issued by another financial institution? If the answer to the second question is in the negative, is Article 135(1)(d) of the VAT Directive, which concerns the exemption from tax of transactions concerning debts, to be interpreted as also covering the case where the former undertaking manages debts transferred to another financial institution? ____________ 1 Council Directive 2006/112/EC of 28 November 2006 on the common system of value added tax (OJ 2006, L 347, p. 1).