Judgment_paragraph 32 · Sonaecom SGPS SA v Autoridade Tributária e Aduaneira (C-42/19)

32As the Advocate General observed in point 30 of her Opinion, a mixed holding company is a company that, in addition to its non-economic holding activity, which consists in the holding of shares in other companies and is not subject to VAT, also carries out an economic activity. According to the case-law, a mixed holding company which not only holds shares in companies, but also supplies remunerated, taxable services to some of those companies, is thus itself a taxable person, albeit entitled to only a pro rata deduction of input tax (see, to that effect, judgments of 27 September 2001, Cibo Participations, C‑16/00, EU:C:2001:495, paragraph 22, and of 13 March 2008, Securenta, C‑437/06, EU:C:2008:166, paragraph 31).