Questione giuridica chiave
Whether golf instruction was supplied by the taxpayer in its own name, requiring proportional input tax reduction for mixed use.
Decisione estratta
The taxpayer itself was the supplier of the golf instruction; no direct representation in the name and for account of the golf school was proven.
Motivazione estratta
It performed the administrative, promotional and collection activities and appeared externally as the provider. The requirements for direct representation under Art. 10 MWSTV were not met and were not documented for each service.