Il principio di neutralità interna nell'IVA

The thesis studies the principle of VAT neutrality in its internal dimension. It focuses on the main aspects of VAT configuration: right of deduction, exemptions and reduced rates. There is also included a theoretical approach of the principle in economic and legal terms, and also a comparison of the various types of indirect taxes that may exist from the point of view of tax neutrality, mainly VAT, cascade taxes and Retail Sales Tax. The aim of the thesis is to concrete the concept of the principle, develop its main economic implications and study its real development in the VAT Directive. From the point of view of the right of deduction and the exemptions it will be made a study of the case-law of the European Court of Justice, and I will deepen into specific questions like the use of mix goods, the consideration of direct and general costs or the ways to exercise the right of deduction (reimbursement and compensation). Moreover it shows the main exceptions to tax neutrality included in the VAT Directive: prohibitions to the right of deduction, exemptions and reduced rates. In this part the study will also be supported by the study of the ECJ's cases. Therefore, the aim of the thesis is to analyse if the VAT Directive accomplishes with the tax neutrality principle, once that we have spycified its concrete meaning and differentiated between its two dimensions: internal and external.