Case C-232/24, Kosmiro: Judgment of the Court (First Chamber) of 23 October 2025 (request for a preliminary ruling from the Korkein hallinto-oikeus – Finland) – in the proceedings brought by A Oy (Reference for a preliminary ruling – Taxation – Common system of value added tax (VAT) – Directive 2006/112/EC – Taxable transactions – Exemption relating to the granting of credit – Article 135(1)(b) – Exemption relating to financial transactions – Debt collection – Article 135(1)(d) – Trade factoring – Invoice factoring)
Date: 2025-10-23
Institutions: Court of Justice
Subjects: VAT, claim, credit, financial services, provision of services, tax exemption, tax law, taxpayer








C_202506479EN.000101.fmx.xml












Official Journal of the European Union


EN
C series













C/2025/6479


15.12.2025






Judgment of the Court (First Chamber) of 23 October 2025 (request for a preliminary ruling from the Korkein hallinto-oikeus – Finland) – in the proceedings brought by A Oy


(Case C-232/24,
                (1)
Kosmiro
                (2)
)

(Reference for a preliminary ruling - Taxation - Common system of value added tax (VAT) - Directive 2006/112/EC - Taxable transactions - Exemption relating to the granting of credit - Article 135(1)(b) - Exemption relating to financial transactions - Debt collection - Article 135(1)(d) - Trade factoring - Invoice factoring)
(C/2025/6479)
Language of the case: Finnish

Referring court

Korkein hallinto-oikeus

Parties to the main proceedings


Applicant: A Oy

Intervening party: Veronsaajien oikeudenvalvontayksikkö

Operative part of the judgment







1.


Article 2(1)(c) and Article 9(1) of Council Directive 2006/112/EC of 28 November 2006 on the common system of value added tax
must be interpreted as meaning that, as regards trade factoring, in the context of which the factor relieves the client of debt recovery operations and of the risk of the debts not being paid,






—


the factoring commission paid for a debt collection service the value of which increases the longer the payment term and the greater the level of risk assumed by the factor and










—


the arrangement fees paid by the client, which correspond to the flat-rate amount paid in order to set up the factoring process and which cover, inter alia, the cost of procedures relating to compliance with the obligations arising from the applicable legislation on money laundering,
constitute the value actually given in return for the supply of services falling within the scope of that directive.














2.


Article 135(1)(b) and (d) of Directive 2006/112
must be interpreted as meaning that:






—


the factoring commission paid for a debt collection service the value of which increases the longer the payment term and the greater the level of risk assumed by the factor and










—


the arrangement fees paid by the client, which correspond to the flat-rate amount paid in order to set up the factoring process and which cover, inter alia, the cost of procedures relating to compliance with the obligations arising from the applicable legislation on money laundering
charged by the factor in the context of trade factoring such as that referred to in the answer in point 1 of the operative part or invoice factoring, which is characterised by the fact that the factor undertakes the recovery and collection of the debts concerned which, without being transferred to that factor, are used as security for the financing provided by the factor to the client, constitute consideration for a single and indivisible service of debt collection, subject to value added tax.














3.


Article 135(1)(d) of Directive 2006/112
must be interpreted as meaning that the exception relating to ‘debt collection’, provided for in that provision, is unconditional and sufficiently precise to have direct effect and, therefore, may be relied on by individuals before the national courts against the State.






(1)  OJ C, C/2024/3447.

(2)  The name of the present case is a fictitious name. It does not correspond to the real name of any party to the proceedings.


ELI: http://data.europa.eu/eli/C/2025/6479/oj
ISSN 1977-091X (electronic edition)