Taxation of Company Directors in the European Union
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This paper analyses the judgment of the Court of Justice of the European Union of December 21, 2023, in Case C-288/22. The European court response to the questions submitted by a Luxembourg court for a preliminary ruling enabled the resolution of an appeal filed by a taxpayer against the Luxembourg tax administration, which had determined that his remuneration as a company director was subject to value-added tax. The European court finally sided with the appellant, obliging the national court to annul the ex officio tax assessment. In addition to analyzing the aforementioned judgment, this paper also considers its implications for the European Union as a whole.
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Introduction
The Luxembourg Registration Duties, Estates, and VAT Authority took the view that the remuneration received by a company director was subject to value-added tax (VAT) on the grounds that it constituted a regular and independent economic activity involving the supply of services and therefore issued an ex officio tax assessment. Dissatisfied with that decision, the taxpayer lodged an appeal, first with the abovementioned tax authority and then, following its rejection, with the District Court of Luxembourg, seeking the annulment of that decision.
Given the lack of precision in the national VAT legislation relevant to this case, the Luxembourg court opted to apply several questions to the Court of Justice of the European Union (CJEU) for a preliminary ruling regarding the interpretation and scope of Articles 9 and 10 of the VAT Directive as applied to the specific circumstances of the case.
In its judgment of December 21, 2023, the CJEU upheld the taxpayer’s arguments and ruled that the remuneration received by company directors is not subject to VAT if the activities carried out in that capacity are not independent in nature. As a result, the national court was obliged to annul the contested tax assessment. This paper discusses the implications of this judgment for Luxembourg and the European Union (EU) as a whole.
CJEU Judgment of 21 December 2023 in Case C-288/22
The Context of the Case
On April 22, 2022, the District Court of Luxembourg applied several questions to the CJEU for a preliminary ruling in the context of a dispute between a Luxembourg taxpayer and the Luxembourg Registration Duties, VAT and Estates Authority concerning a VAT assessment levied on remuneration received by the taxpayer in respect of his activities as a director of some companies. The purpose of these questions was to determine whether the taxpayer qualified as a taxable person under the definitions set forth in Articles 9 and 10 of Council Directive 2006/112/EC of November 28, 2006, on the common system of value-added tax (VAT Directive).
The taxpayer was a director of some companies in Luxembourg and performed numerous duties in this capacity. His activities included receiving reports from senior management and representatives of the companies, engaging in discussions on strategic initiatives, selecting operational managers, and addressing financial matters concerning those companies. Additionally, he evaluated potential risks and participated in decision-making processes related to the companies’ accounts and proposals to be submitted to shareholder meetings, risk policy, and, more generally, decisions on the strategy to be pursued by the companies.
On account of these activities, and in his capacity as a director of the companies concerned, the taxpayer had received fees as a percentage of the profits made by those companies, as decided by the respective general meetings of shareholders. It transpired that the taxpayer received an ex officio tax assessment for VAT purposes, issued by the Luxembourg Registration Duties, VAT and Estates Authority, on the grounds that, for tax purposes, company directors carry out, in every possible circumstance, the economic activity of providing services on a permanent and independent basis.
Disagreeing with the decision, the taxpayer lodged an appeal with the same tax authority, which was rejected. He then appealed to the District Court of Luxembourg. In both cases, he argued that his remuneration as a company director was not subject to VAT because he was not acting in an independent capacity but as a member of the board of directors. In contrast, the Luxembourg tax authority took the view that the taxpayer received a remuneration which was decided by the general meeting of shareholders on a proposal from the board of directors, part of which was paid in the form of an administration fee, which meant that the company directors had an interest in the proper conduct of the company’s affairs, even if they were not shareholders, which demonstrated the independent nature of their activity.
In view of the lack of precision in the national VAT legislation concerning companies and the remuneration paid by them, the Luxembourg court opted to suspend the proceedings and refer the following questions to the CJEU for a preliminary ruling concerning the interpretation of Articles 9 and 10 of the VAT Directive:
1. Is a natural person who is a member of the board of directors of a public limited company incorporated under Luxembourg law carrying out an “economic” activity within the meaning of Article 9 of the VAT Directive, and more specifically, are percentage fees received by that person to be regarded as remuneration paid in return for services provided to that company?
2. Is a natural person who is a member of the board of directors of a public limited company incorporated under Luxembourg law carrying out his or her activity “independently”, within the meaning of Articles 9 and 10 of the VAT Directive?
The Regulatory Framework
To examine the applicable regulatory framework in this case, the following section first sets out the provisions of Luxembourg law governing the position of board members and directors of commercial companies in relation to their duties and activities. It then examines how those activities are taxed under the national VAT rules as interpreted by the Luxembourg tax authority. Finally, it describes Articles 9 and 10 of the VAT Directive and their general interpretation by the CJEU.
Luxembourg Company Law
Article 441-1 of the Luxembourg Commercial Companies Code, dated August 10, 1915, as amended, stipulates that public limited companies are managed by agents appointed for a defined term, who may or may not hold shareholder status, and who may be dismissed from their position and compensated or not. The second subparagraph of this article specifies that the board must consist of at least three directors appointed by the general meeting of shareholders for a term not exceeding six years, with the possibility of removal at any time by the general meeting.
Article 441-5 further establishes that the board of directors is vested with the authority to undertake all actions necessary or useful to fulfill the company’s purpose, except for those powers explicitly reserved by law or the articles of association to the general meeting. This includes representing the company in relation to third parties and in legal proceedings, whether as plaintiff or defendant. However, the articles of association may grant authority to one or more directors, either individually or jointly, to represent the company in or outside of court.
Pursuant to sub-paragraphs 8 and 9 of the same article, the directors are not personally liable for the company’s obligations but are accountable to the company for the execution of their mandate and for any misconduct in managing its affairs. Nevertheless, the directors and members of the management committee are jointly and severally liable to the company or third parties for any damages arising from violations of the Luxembourg Commercial Companies Code or the articles of association.
The daily management of the company’s affairs and the authority to represent the company in relation to such management may be delegated to one or more directors, officers, managers, or other agents, regardless of shareholder status, who may act alone or jointly. The liability of those entrusted with daily management is governed by the general rules pertaining to mandates (Article 441-10). The articles of association may permit the Board of Directors to delegate its management powers to a management committee or a managing director; however, this delegation must not include the overall policy of the company, or any actions explicitly reserved for the Board of Directors by other legal provisions (Article 441-1).
Luxembourg VAT Law
According to Article 4.1 of the Luxembourg VAT Law of February 12, 1979, as amended, a taxable person for VAT purposes is defined as any individual who engages in transactions independently and regularly as part of an economic activity, regardless of the objective or outcomes of that activity and irrespective of its location. According to Article 5 of the same law, economic activity is any activity intended to generate income, including production, trade, and the provision of services, as well as mining and agricultural activities, the operations of independent professionals, and activities involving the utilization of tangible or intangible assets for the purpose of generating income on an ongoing basis.
In the case in question here, the Luxembourg Registration Duties, VAT and Estates Authority concluded that the company directors in Luxembourg engage in economic activity on a regular and independent basis, which means that the remuneration they receive in this capacity cannot be exempt from VAT. Consequently, in Luxembourg, the board members of commercial companies must therefore pay and charge VAT to the legal entity of which they are a member. This activity is considered to be regular or permanent since board members are appointed for terms of up to six years and are independent due to the fact that their compensation is determined by the general meeting of shareholders based on a proposal from the board of directors, part of which is allocated as an administration fee. This arrangement suggests that board members possess a vested interest in the proper management of the company’s affairs, even if they do not hold shareholder status.
The VAT Directive
According to Article 9 of the VAT Directive, a “taxable person” is any individual who engages in an economic activity independently, regardless of the location, purpose, or outcomes of that activity. For its part, an “economic activity” encompasses any actions undertaken by producers, traders, or service providers, including mining and agricultural operations, as well as activities conducted by independent professionals. Specifically, the continuous exploitation of tangible or intangible assets for the purpose of generating income is recognized as an economic activity.
As demonstrated by CJEU case law, the wording of this article underscores the expansive nature of the concept of “economic activity” in the sense that the activity is considered in itself, irrespective of its purpose or results.1 1 See judgment of 15 April 2021 in Case C-846/19, judgment of 25 February 2021 in Case C-604/19 and judgment of 16 September 2020 in Case C-312/19. Consequently, to ascertain whether a service is rendered for remuneration-in which case the activity is to be considered an economic activity-all the conditions under which it is provided must be analysed.2 2 See judgment of 15 April 2021 in Case C-846/19, judgment of 12 May 2016 in Case C-520/14 and judgment of 19 July 2012 in Case C-263/11.
According to Article 10 of the VAT Directive, the requirement that the economic activity be conducted independently disbars employees and similar individuals from VAT obligations, provided they are bound to their employer by an employment contract or other legal arrangements that establish an employer-employee relationship concerning working conditions, remuneration, and the employer’s liability.
As the CJEU has previously clarified,3 3 See judgment of 13 June 2019 in Case C-420/18. independent taxable persons are typically characterized by their assumption of economic risk. They are accountable for both profit and loss, determine the scope of their activities, and are solely responsible for their success or failure, as they have the autonomy to choose which risks to take. This is not the case with employees, as it is the business owner alone who assumes the economic risk and takes the initiative.
Therefore, for VAT purposes, the duties and working conditions of board members and directors of companies have to be examined in each case in order to assess whether they are both permanent and independent, which is necessary to determine whether they are taxable or not.
Gist and Operative Part of the CJEU’s Judgment
The two questions referred to the CJEU for a preliminary ruling, which must be dealt with together, essentially ask whether the remuneration received by a member of the board of directors of a company in respect of his or her activity as a member of a body which is part of a legal entity constitutes an independent economic activity within the meaning of Article 9 of the VAT Directive, and in what circumstances that activity is to be regarded as independent within the meaning of Article 10 of that directive.
First, the Court states that if the conditions laid down in Articles 9 and 10 of the VAT Directive are met –that is to say if a company director provides a service and thus makes an independent economic activity, irrespective of the purpose or results of that activity– then he or she is a taxable person. However, it also asserts that to ascertain whether the provision of services for remuneration constitutes an economic activity, it is essential to consider all the conditions under which the activity is performed.
In this respect, the CJEU held that, in the present case, the taxpayer was not remunerated for his own activity (as, for example, in the case of an instructed lawyer who would be liable if his or her advice was wrong), but rather in his capacity as a member of a collective body. Moreover, the amount of his remuneration was not determined by negotiation with the recipient of the services, as is generally the case in companies, but was unilaterally fixed by the general meeting of shareholders, which is another governing body of the company.
The Court also held that the actions undertaken by the taxpayer as a company director could not be hired out to third parties on the open market. On the contrary, the only possible recipient was the company of which he was appointed a board member. In that regard, his activity would be limited by Luxembourg company law, which confers certain rights and obligations on the collegiate body and its members in their relations with the company.
Article 441-8 of the Luxembourg Commercial Companies Code considers the company directors are not personally liable for the company’s commitments. For the Court, this would mean that liability would not fall on the board member personally, but in principle only on the body of which he was a member, thus excluding any personal assumption of risk.
Although the board member did not have a classic employer-employee relationship with the company in the strict sense of Article 10 of the VAT Directive, this did not have to be the case for him to be exempt. According to the Court, in order to assess the existence of such an employer-employee relationship, it is essential to determine whether the individuals in question conduct their activities in their own name, for their own account, and under their own responsibility, as well as whether they bear the economic risks related with such activities.
If these determinations show that the board member is not acting under his own responsibility, it must be concluded that he is, in fact, acting primarily on behalf of the board of directors and, more broadly, on behalf of the company to which the board belongs, even if he appears to be acting in his own name when he submits guidelines or proposals to the board of directors and when he votes. This applies to the extent that such guidelines, proposals, and votes, which may primarily give rise to liability on the part of the company, are formulated in the interest of and on behalf of the company.
As regards the question of a company directors in Luxembourg bears the economic risk inherent in their role, the Court indicated that when an individual, such as the taxpayer, contributes expertise and knowledge to the board and participates in its voting process, they do not appear to bear the economic risks associated with their activity. This is because it is the company itself that is responsible for the negative consequences of the board’s decisions and for any economic risks arising from the actions of its members.
The Position of the CJEU in this Case
The CJEU emphasized that this conclusion is justified when the national regulatory framework clearly indicates that company directors do not incur personal liability for the company’s debts. Even if the percentage remuneration received by them depends on the profits made by the company, they do not bear any risk of loss linked to their activity since the general meeting of shareholders grants their percentage remuneration, which is paid even if the company makes a loss or goes into judicial liquidation.
The Court, therefore, concluded that the activities of company directors in Luxembourg are not independent for VAT purposes if these members do not operate in their own name or assume personal responsibility and do not bear the economic risks related with their roles, even if they are free to choose how and when to carry out their work, may themselves receive the remuneration which constitutes their income, may act in their own name and are not subject to any hierarchical subordination.
This judgment of the CJEU put an end to the criterion previously applied by the Luxembourg tax authority, which classified the activities of company directors as always subject to VAT. As a result, according to this judgment, the activities described will not be classified for tax purposes as the supply of independent services if, after analysing the specific conditions in which they are carried out within the companies, it is determined that company directors do not operate for their own account or assume responsibility and do not bear the economic risks related to their activities.
Consequently, in the light of the answers to the questions referred to the CJEU for a preliminary ruling, the District Court of Luxembourg was obliged to uphold the taxpayer’s appeal and annul the VAT assessment issued ex officio by the Luxembourg tax authority. As the scope of the judgment is not expressly defined, it must be applied not only to all similar cases from the date of the judgment but potentially also to earlier acts. This is pursuant to the general rule that CJEU judgments have retroactive effect4 4 Those in favour of the retroactivity of CJEU judgments include Pérez Daudí (2017), De la Tejera Hernández (2014) and Louis (1983). unless their scope is defined. However, such a possibility is subject to Luxembourg provisions on the review of final acts.
Other Implications of the CJEU Judgment for the EU
The Case Law of the CJEU as a Harmonization Factor
The judgments of the CJEU are undoubtedly crucial for the legal systems of the EU Member States, as both courts and authorities are obliged to respect and take account of them, reflecting the principle of the primacy of EU law.5 5 On the primacy of EU law, see Marco Abato (2017). In relation to this principle, Núñez Lozano (2017) emphasizes that CJEU judgments must be heeded and implemented by the States, as they are essential for defining the obligations imposed by the principles of primacy and direct effect of EU law. Moreover, the CJEU has repeatedly stressed that citizens’ rights derive from the EU rules themselves and not from its judgments, as these rules are directly applicable to domestic law in the Member States.6 6 See, inter alia, the judgements of the CJEU of 14 December 1982 in Case 314/81 and of 5 March 1996 in Case C-46/93.
When CJEU judgments annul national provisions for being contrary to EU law, they have an undeniable purifying effect on the domestic legal system, identical to the constitutional control exercised by the Member States themselves. According to Núñez Lozano (2017), the “purification of administrative acts is not so much a direct consequence of the judgment as an indirect effect of it, grounded in the principles of loyal cooperation and of primacy and direct effect. And it should be noted here that purification may be brought about not only by a judgment of the Court directly affecting the act but also as a result of any judgment [of any State] if it follows from its judicial opinion or operative part that the judgment is valid, even if its proper execution does not affect the act”.
However, these judgments not only resolve conflicts between EU and national law but also prevent the introduction of new national rules that may conflict with EU law. The CJEU’s jurisprudence thus promotes the harmonization of national laws in two ways: one negative, by striking down provisions that contradict European law, and the other positive, by delineating the boundaries of a shared legal framework.7 7 On the harmonisation of EU jurisprudence, see Villar Ezcurra (2011). Even judgments on questions referred to the CJEU for a preliminary ruling, which do not go so far as to invalidate national acts, may influence national judges’ views on the compatibility of the cases before them with EU law.
According to the Advocate General’s opinion in this case, many Member States subject the income (remuneration) of the bodies of a company to income tax only without considering whether they may be carrying out an independent economic activity. Of the thirteen Member States which also have legislation or case law on the VAT treatment of such remuneration paid to the bodies of another taxable person, six generally do not consider it to be an economic activity subject to VAT, while the other six do so under certain conditions. Luxembourg is the only country that consistently treats these bodies or their members as exercising an independent economic activity. The implication of the judgment is, therefore, uniform tax treatment across all Member States.
The Principle of VAT Neutrality
According to the principle of VAT neutrality,8 8 On the principle of neutrality, see Macarro Osuna (2015). economic operators engaged in identical transactions within the EU cannot be treated differently with regard to VAT taxation.9 9 Although the principle of VAT neutrality is arguably rooted in Article 20 of the Charter of Fundamental Rights of the European Union, which asserts that all individuals are equal before the law, it is frequently cited and applied in EU case law, for example in judgment of 28 June 2007 in Case C-363/05, judgment of 4 May 2006 in Case C-169/04, judgment of 3 April 2003 in Case C-144/00 and judgment of 10 September 2002 in Case C-141/00. For Veiga Calvo (2014), “VAT neutrality means that the taxation required of all intermediaries in the value chain of the product or service until it reaches the final consumer does not create distortions, since the deduction mechanism guarantees that the tax levied and charged by an operator intervening in the value chain is fully recoverable by the next intervener, provided that certain conditions are met.” Similarly, according to García Novoa (2010), “the VAT model differs from the cascading of indirect taxes in that the economic burden on the operator subject to it is completely eliminated, which is achieved through the deduction of input VAT. This is a consequence of neutrality, which is directly linked to the deductibility of input tax for those who carry out taxable and non-exempt transactions. The neutrality of the tax burden is therefore a defining feature of the VAT model”.
This principle dictates that the legal form in which producers or service providers carry out their activities should not be relevant for determining whether the goods or services are similar. Since VAT must be neutral between competitors, it would be contrary to this principle if taxation were contingent upon the legal structure utilized by taxable persons in conducting their activities. However, Paredes Gómez (2006) points out that “the main factor that causes a breach of fiscal neutrality in the choice of the legal form of the company is the difference in the nominal tax rates applied to the individual entrepreneur and the company”, so the principle of neutrality would not only apply to VAT.
If the activity of a member of a company body is in itself a taxable activity, that member would have to charge VAT to the company on the remuneration received. If the company qualifies as a taxable person entitled to full input tax deduction, this would not be a problem as the company, acting as a tax collector on behalf of the State, should be fully relieved of the final VAT burden. According to Pawel Slowinski (2022), “it should always be borne in mind that the purpose of the deduction scheme is to relieve the entrepreneur of the full burden of the VAT due and that the common VAT system, therefore, ensures neutrality of the tax burden.”
If, instead, the company were a taxable person with no right of deduction or only a partial right of deduction, the activity of statutory bodies would entail an additional cost for the company, a cost which would affect all companies required by law to act through such bodies. Given that there are also taxable persons who are not obliged to have such bodies (e.g., the self-employed), this would create a disparity in VAT treatment among competing economic operators engaged in the same transactions, leading to the unequal tax treatment that contravenes the principle of neutrality. According to Martínez Muñoz (2010), this is because VAT neutrality must be applied in such a way that there is neutrality in competition so that goods and services of a similar nature bear the same tax burden, allowing only those discriminations that do not entail a distortion of competition.
In the context of the current judgment, the principle of neutrality would be violated since VAT must be neutral between competitors. If the operation of the body were enough to determine the presence of economic activity, taxable persons who do not have the right to deduct would have to bear an additional burden of VAT simply because of their legal form. In contrast, taxable persons whose legal form allows them to dispense with such a body would not have to bear this VAT, nor would they have to pass it on to their final customers. Domínguez Barreroet al. (2005) note that “the comparative literature has dealt extensively with this issue, both from a theoretical and applied perspective, confirming that personal and corporate income taxes influence the way in which business activity is organized.”
In the present case, the principle of VAT neutrality would require the non-taxation of the statutory activities of a company’s bodies, as this is the only way to ensure tax neutrality for competing companies with different legal forms. Therefore, the principle of VAT neutrality could also be called to consider that the remuneration paid for the activity of a company’s bodies should not be taxed as such, as this could distort competition between companies carrying out the same transactions at the EU level.
Conclusions
The CJEU judgment studied in this paper clarifies whether the remuneration received by the company directors in Luxembourg is always subject to VAT, as was the view of the Luxembourg Registration Duties, VAT, and Estates Authority. According to the judgment, the activity of such members is not subject to VAT because the members do not exercise their activity independently, they do not act on their own behalf or assume personal responsibility, nor do they bear the economic risks associated with their activities. Consequently, in the present case, the ex officio tax assessment should be annulled.
Since this is a judgment of a European Supreme Court, its effects apply not only to the case in question but also to all similar cases that may arise both in Luxembourg and other Member States of the European Union. It is important to note the primacy of EU law, which must be adhered to by both courts and national authorities in their actions and decisions. Similarly, the decisions of the CJEU generally have retroactive effect, unless otherwise specified, although this possibility is subject to national rules on the review of final acts.
Additionally, the principle of VAT neutrality is crucial, as it ensures that economic operators engaged in the same transactions within the EU are treated equitably for VAT purposes. In this case, neutrality would be undermined if company bodies were taxed differently under national laws, potentially leading to distortions in competition between them.
The value of this and other CJEU judgments for the EU as a whole is unquestionable, as their operational part is binding on all Member States. This is not only because it obliges national authorities to adapt their rules and decisions to the same criteria but also because it facilitates the harmonization of national legal systems. This occurs in two ways: one negative way, by abolishing provisions that conflict with EU law, and the other positive, by delineating the boundaries of a shared legal framework.
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