The Resource When one becomes two : the forlorn future of the fixed establishment

When one becomes two : the forlorn future of the fixed establishment

Label
When one becomes two : the forlorn future of the fixed establishment
Title
When one becomes two : the forlorn future of the fixed establishment
Creator
Subject
Language
  • eng
  • eng
Summary
A permanent establishment is a well-known concept in corporate and tax law. It is also widely agreed that a permanent establishment is the same legal entity as its head office. However, when considering the application of value added tax (VAT) to such a concept, the waters become muddied. There is ground-breaking case law on which taxpayers currently rely in order to treat supplies between a head office and its fixed establishment, as the concept is referred to in VAT circles, as falling outside the scope of VAT, based on the single-entity principle. Nevertheless, recent developments at the Court of Justice of the European Union (ECJ), the European Commission and - most recently - the OECD, may require financial institutions to put their thinking caps on and restructure some of their VAT affairs as attempts are made to split a single entity into two. This is not necessarily due to any perceived negative consequences of these developments, but rather the unintended consequences. This article discusses these developments and considers the possible consequences and VAT impact on financial institutions
Citation source
In: Derivatives and financial instruments. - Amsterdam. - Vol. 16 (2014),
http://library.link/vocab/creatorName
Heydari, S
Language note
English
http://library.link/vocab/subjectName
  • PE
  • VAT
  • head office
  • branch
  • ECJ case law
Label
When one becomes two : the forlorn future of the fixed establishment
Instantiates
Publication
Note
20140731
Other control number
dfi_2014_03_int_3.html
Label
When one becomes two : the forlorn future of the fixed establishment
Publication
Note
20140731
Other control number
dfi_2014_03_int_3.html

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