VAT on Credit Management after Loan Assignment: Takeaways from the Judgement of the General Court of the European Union in case T-184/25 dated 17 June 2026

23 June 2026

The General Court of the European Union has confirmed that credit management services (servicing) provided by a loan originator to the transferee for consideration after it has transferred the underlying loans are not VAT-exempt under any of the financial services exemptions in Article 135 (1) (b) to (d) of the EU VAT Directive 2006/112/EC.

For securitisation structures where the originator continues to service transferred loans this ruling raises significant questions regarding the VAT treatment of the servicing fee and, even where the fee is embedded in the purchase price. Affected parties should review existing and proposed transactions without delay.

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