In the context of their accession, Bulgaria and Romania were authorised to grant a tax exemption to small enterprises and to continue applying a VAT exemption to the international transport of passengers. For the purposes of clarity and consistency, those exemptions should be incorporated into the Directive itself. The legality and necessity of those exemptions should be reviewed at least every two years.

In the context of their accession, Bulgaria and Romania were authorised to grant a tax exemption to small enterprises and to continue applying a VAT exemption to the international transport of passengers. For purposes of clarity and consistency, these exemptions should be incorporated into the Directive itself.

Regarding the right of deduction, the basic rule is that this right arises only in so far as the goods and services are used by a taxable person for the purposes of the transactions of that person which give rise to a right of deduction . That rule should be clarified and strengthened with respect to the supply of immovable property in order to ensure that taxable persons are treated in an identical manner whenever immovable goods that they use for their business activity are not used exclusively for purposes related to that activity. Consequently, the initial exercise of the right of deduction should be limited to that use which results in transactions giving rise to a right of deduction when the tax becomes chargeable.

Regarding the right of deduction, the basic rule is that this right arises only in so far as the goods and services are used by a taxable person for the purposes of his business activity . This rule should be clarified and strengthened with respect to the supply of immovable property and expenditure relating thereto in order to ensure that taxable persons are dealt with in an identical manner whenever immovable goods that they use for their business activity are not used exclusively for purposes related to that activity.

Since immovable property and related expenditure account for the most significant cases where clarification and strengthening of the rule is appropriate, given the value and economic lifetime of such property and the fact that mixed use of this type of property is a common practice, the initial right of deduction should be applied to immovable property supplied to the taxable person and important services relating thereto, which, by virtue of their economic value, can be assimilated to the acquisition of immovable property . Conversely, minor repairs or improvements of limited economic significance should be excluded from the scope of the rule.

Whilst immovable property and related expenditure account for the most significant cases where clarification and strengthening of the rule is appropriate, given the value and economic lifetime of such property and the fact that mixed use of this type of property is a common practice, it is nevertheless appropriate, in accordance with the principle of subsidiarity, to authorise Member States to apply the same rule to movable goods with a durable nature and forming part of the business assets .

With a view to ensuring an equitable deduction system for taxable persons in the context of the new rules, an adjustment system in accordance with the rules on adjustment of deductions should be provided for which takes into account changes in the business and non-business use of the property concerned for a period corresponding to the existing adjustment period for immovable property acquired as capital goods .

With a view to ensuring an equitable deduction system for taxable persons in the context of the new rules, an adjustment system in accordance with the other rules on adjustment of deductions should be provided for which takes into account changes in the business and non-business use of the property concerned.

1. In the case of immovable property forming part of the business assets of a taxable person and used both for purposes of the taxable person's business and for his private use or that of his staff, or, more generally, for purposes other than those of his business, VAT on expenditure related to this property shall be deductible in accordance with the principles set out in Articles 167, 168, 169 and 173 only up to the proportion of the property's use for purposes of the taxable person's business . By way of derogation from Article 26, the changes in the proportion of use of immovable property referred to in the first subparagraph shall be taken into account in accordance with the principles provided for in Articles 184 to 192 as applied in the respective Member State .