Secondment of staff at cost was a taxable supply: San Domenico Vetraria SpA (C-94/19)

This case concerned whether secondment of staff to a subsidiary, which reimburses only the related costs, is within the scope of VAT. The ECJ had little difficulty in holding that the supply was made in return for the amount paid, i.e. there was a direct link between the supply and the consideration, and the fact that the payment was lesser than, or greater than, or equal to the cost of making the supply was not relevant. The secondment was therefore a taxable supply.