Kernrechtsfrage
Whether administrative and management services performed for affiliated funds and third parties are exempt from VAT under the social security exemption.
Extrahierter Entscheid
Such services are not exempt merely because they are performed by a social security institution; they are taxable as separate services to third parties.
Extrahierte Begründung
The exemption for social security services is construed restrictively and covers the core insurance-related services, including their inseparable ancillary administration. By contrast, mandate-based services for separate legal entities are taxable upstream services and do not lose taxability because the recipient uses them for an exempt purpose.