Judgment_paragraph 31 · Direktor na Direktsia „Obzhalvane i danachno-osiguritelna praktika“ - Sofia v „Iberdrola Inmobiliaria Real Estate Investments“ EOOD (C-132/16)

31It is apparent from the case-law of the Court that, in the context of the direct-link test that is to be applied by the tax authorities and national courts, they should consider all the circumstances surrounding the transactions concerned and take account only of the transactions which are objectively linked to the taxable person’s taxable activity. The existence of such a link must thus be assessed in the light of the objective content of the transaction in question (see, to that effect, judgment of 22 October 2015, Sveda, C‑126/14, EU:C:2015:712, paragraph 29).