The Court of Justice of the European Union, in its judgment of 25th February 2021 in case C-604/19, acknowledged that the conversion of the right of property’s perpetual usufruct into a right of property’s full ownership provided for in national law in return for payment of a fee constitutes a supply of goods, and a local self-government unit being
a collector of that fee acts as a taxpayer and not as a public authority. The author tries to answer the question of whether, in the light of the above decision, it is permissible for the conversion fee to be subject to value-added tax in a situation where the perpetual usufruct of the property was established before the 1st May 2004.