20In that regard, it must be recalled that, within the framework of the VAT system, taxable transactions presuppose the existence of a transaction between the parties in which a price or consideration is stipulated. Thus, where a person’s activity consists exclusively of providing services for no direct consideration, there is no basis of assessment and the services are therefore not subject to VAT (see judgments of 3 March 1994 in Tolsma, C‑16/93, EU:C:1994:80, paragraph 12; 29 October 2009 in Commission v Finland, C‑246/08, EU:C:2009:671, paragraph 43; and 27 October 2011 in GFKL Financial Services, C‑93/10, EU:C:2011:700, paragraph 17).
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