A subsidiary cannot be a fixed establishment (FE) under EU VAT in (almost) any case. This is a (quite) reassuring takeaway for VAT businesses from the much-awaited decision by the Court of Justice of…
Some cases just have it all; the Apple case is one of them. First, size: at more than thirteen billion euros, the recovery order Ireland had to enforce dwarfed the previously biggest one (EDF, at…
In its judgment of January 21, 2020 (Santander case, available here), the European Court of Justice (ECJ) not only prevented the Spanish Central Tax Tribunal (Tribunal Económico-Administrativo…
A subsidiary can (also) be a fixed establishment (FE) of its parent company under European (EU) VAT, after all. This is the most immediate conclusion as it emerges from the much-awaited decision by…
Tax Issue Under Review
On 6 February 2020 (case no. 2C_510/2018), the Swiss Federal Supreme Court rendered a decision on the tax qualification of a pension plan benefit paid from a Swiss pension plan…
On 14 November 2019, AG Kokott released her opinion in Dong Yang Electronics (Case C-547/18), referred to the Court of Justice of European Union (CJEU) by the Regional Administrative Court of Wroclaw…