Can VAT Exemptions Cover NGO Suppliers?

Pro Publico facilitated a successful collaboration between a Brussels-based civil society organisation and the international law firm Freshfields, enabling a strategic legal assessment on the VAT implications of delivering services to the European Commission.

A VAT Question with Global Implications

Legal uncertainty can hinder mission-critical opportunities for organisations working to strengthen democratic values worldwide. In this instance, a civil society actor was exploring the possibility of providing professional services to the European Commission. A key legal question arose: do the EU institutions’ VAT exemptions extend to third-party suppliers contracted under such agreements?

Operating globally, Facing Complexity

The organisation in question operates internationally. Though generally exempt from VAT when contracting directly with EU institutions, it was unclear whether this exemption also applied to external experts engaged as part of the service delivery. The lack of clarity posed a risk to operational and financial planning and raised fundamental questions about the feasibility of entering into the proposed agreement.

Freshfields Provides Legal Clarity on a Pro Bono Basis

Through their European pro bono manager Karina Fletcher – the organisation was connected to Freshfields’ Brussels office, where pro bono support was provided by Nikolaas Van Robbroeck and Alessandro Vullo. This legal team quickly delivered both oral and written guidance, helping the organisation assess whether VAT registration would be necessary to fulfil the potential contract. Their expert advice enabled a fully informed decision aligned with the organisation’s non-profit mission and administrative structure.

“The overall support was very useful and timely,” said their representative. “VAT is a sophisticated topic, and we felt we received professional, impartial and clear advice. It’s incredibly reassuring to have someone to turn to for legal guidance – especially when such quality support is provided pro bono publico.”

Why This Matters

This case illustrates how targeted pro bono legal advice empowers civil society to navigate complex EU frameworks, avoid legal pitfalls, and stay focused on their mission. Pro Publico is proud to enable such collaborations, connecting CSOs with legal expertise that might otherwise be inaccessible.

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Thanks to @NikolaasVanRobbroeck @AlessandroVullo @KarinaFletcher @Freshfields @ProPublico @FrancescoZatelli

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