Kernrechtsfrage
Whether sponsorship receipts from sponsor associations were fully subject to VAT or had to be split into taxable advertising and non-taxable donation parts.
Extrahierter Entscheid
The payments were taxable consideration for advertising/publicity services; no split into sponsorship and donation was required.
Extrahierte Begründung
VAT depends on an exchange of services for consideration. The club’s naming of sponsoring companies in match programmes and the official magazine was economically linked to the sponsors’ payments and amounted to publicity services. The absence of a strictly enforceable contractual claim did not matter, and the practice of commercial sponsors financing image-related publicity supported qualification as taxable consideration.