Questione giuridica chiave
Whether services performed in the delegated scope of an AHV compensation fund are exempt from VAT under the social security exemption.
Decisione estratta
No. Services rendered in a delegated scope for affiliated institutions are not services of social security within the meaning of the exemption.
Motivazione estratta
The exemption in Art. 14 No. 7 MWSTV is construed restrictively. Even if the recipient is a social insurance institution, the services are pre-supplies or mandate-based activities and remain taxable when performed by a private entity.