On November 12th, 2015, the German Federal Tax Authority published an amendment of the VAT Application Decree. The Decree now adopts the same wording set forth in the VAT Code for the tax exemption of the management of investment funds, § 4 No. 8 (h) VAT Code. In addition, the amendment clarifies that the tax exemption also applies to the performance of risk management. In our view, the VAT Decree violates EU Law.