The Resource When one becomes two : the forlorn future of the fixed establishment
When one becomes two : the forlorn future of the fixed establishment
Resource Information
The item When one becomes two : the forlorn future of the fixed establishment represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.This item is available to borrow from 1 library branch.
Resource Information
The item When one becomes two : the forlorn future of the fixed establishment represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.
This item is available to borrow from 1 library branch.
- 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
- Language
- eng
- Label
- When one becomes two : the forlorn future of the fixed establishment
- Title
- When one becomes two : the forlorn future of the fixed establishment
- Language
- 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
- Label
- When one becomes two : the forlorn future of the fixed establishment
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<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/portal/When-one-becomes-two--the-forlorn-future-of-the/cGxf_tFMrYw/" typeof="Book http://bibfra.me/vocab/lite/Item"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/portal/When-one-becomes-two--the-forlorn-future-of-the/cGxf_tFMrYw/">When one becomes two : the forlorn future of the fixed establishment</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="https://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
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<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/portal/When-one-becomes-two--the-forlorn-future-of-the/cGxf_tFMrYw/" typeof="Book http://bibfra.me/vocab/lite/Item"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/portal/When-one-becomes-two--the-forlorn-future-of-the/cGxf_tFMrYw/">When one becomes two : the forlorn future of the fixed establishment</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="https://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
