Judgment of the Court (Seventh Chamber) of 2 October 2025 (request for a preliminary ruling from the Administrativen sad Veliko Tarnovo – Bulgaria) – ‘Svilosa’ AD v Direktor na Direktsia ‘Obzhalvane i danachno-osiguritelna praktika’ – Veliko Tarnovo

(Case C-535/24,  (1) Svilosa)

(Reference for a preliminary ruling - Taxation - Common system of value added tax (VAT) - Directive 2006/112/EC - Article 2(1)(c) - Supply of services for consideration - Article 24(1) - Supply of services - Article 26(1)(b) - Supply of services free of charge that are to be treated as a supply of services for consideration - Debt recovery - Debt recovery in favour of a third party)

(C/2025/6145)

Language of the case: Bulgarian

Referring court

Administrativen sad Veliko Tarnovo

Parties to the main proceedings

Applicant: ‘Svilosa’ AD

Defendant: Direktor na Direktsia ‘Obzhalvane i danachno-osiguritelna praktika’ – Veliko Tarnovo

Operative part of the judgment

Article 2(1)(c) and Article 26(1)(b) of Council Directive 2006/112/EC of 28 November 2006 on the common system of value added tax must be interpreted as meaning that actions taken by a creditor to recover a debt where those actions were taken without authority or mandate from the debtor may not be classified as a ‘supply of services for consideration’ and are not to be treated in the same way as that concept for the purposes of those provisions.

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(1)  OJ C, C/2024/6633.