by their staff, shall be regarded as non taxable persons. Definition of the concept of admission to cultural events (Art. 32-33 Reg.) Art. 32 and Art. 33 of the Regulation define the right of admission within the meaning of Art. 53 of the VAT Directive to cultural and similar events and services. The Regulation distinguishes between services in respect of admission to events (cf. Art. 32 Reg.) and the ancillary services (cf. Art. 33 Reg.). Art. 32 of the Regulation shall be applicable for the therein specified services except the use of facilities such as gymnastics halls and suchlike, in exchange for the payment of a fee (cf. Art. 32 No. 3 Reg.). Art. 33 of the Regulation includes services which are directly related to admission to events and includes in particular the use of sanitary facilities but shall not include mere intermediary services relating to the sale of tickets. Advantages and disadvantages The Regulation provides more clarity concerning special concepts of the VAT Directive, which was necessary in respect to a uniform application within the European Union. The Implementing Regulation is a sign for the inexactitude of the legislator when drafting the VAT Directive. The resulting inadequacies are indented to be corrected by the presented Regulation. Furthermore, the Implementing Regulation – being an equal regulation in comparison to the VAT Directive – will not lead to a better transparency or overview. In most cases it would have been wiser to transform the VAT Directive itself in respect to the necessary changes. References External links Implementing Regulation (EU) No 282/2011 of 15 March 2011 General overview - European VAT system (European Commission) VAT number validation (European Commission) European Union regulations 2011 in law 2011 in the European Union Tax legislation