Outsourced services rendered to management companies may be VAT exempt

In the last twelve months the Italian Revenue Agency released three letter rulings concerning the scope of the VAT exemption for the management of special investment funds (laid down by Article 135, para. 1, let. g) of the VAT Directive) and its application to outsourced services.
The VAT exemption at stake is dependent upon two conditions: (i) the services in question (which might also be outsourced by the fund manager to third-party service providers) must qualify as “management” services; and (ii) such services must be supplied in respect of investment undertakings qualifying as “special investment funds”.
The three public rulings – two of which issued in response to ruling requests filed by our firm – dealt with both the concepts of “management” and “special investment funds” contained in the VAT exemption provision, and clarified the following.