Questione giuridica chiave
Whether input tax on Vietnam project costs linked to a participation could be deducted
Decisione estratta
No. The costs were directly linked to a holding participation and not to taxable output transactions, so the input tax deduction was correctly refused.
Motivazione estratta
Input tax is deductible only when used for taxable outputs or other qualifying purposes. Costs fully attributable to non-taxable participation activities or non-business use do not qualify.