Legitimate expectation, directors’ fees, fixed establishments, reforming the TMO... Craig Kirkham-Wilson and Gary Barnett (Simmons & Simmons) examine recent developments in the VAT world.
Fixed establishments and toll manufacturing
The CJEU has considered the scope of the concept of a fixed establishment in the context of a parent utilising (exclusively) the toll manufacturing services of a subsidiary in Cabot Plastics Belgium v Belgium (Case C-232/22). The court has held that the mere fact that the subsidiary provides its services exclusively to its parent does not mean that the subsidiary will amount to a fixed establishment of the parent for VAT purposes.
Cabot Plastics Belgium (Cabot Belgium) provided toll manufacturing services to its parent company Cabot Switzerland established in Switzerland. Toll manufacturing involves in essence the provision of manufacturing and production services to materials or semi-finished products provided by the customer.
Pursuant to the toll manufacturing agreement...
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Legitimate expectation, directors’ fees, fixed establishments, reforming the TMO... Craig Kirkham-Wilson and Gary Barnett (Simmons & Simmons) examine recent developments in the VAT world.
Fixed establishments and toll manufacturing
The CJEU has considered the scope of the concept of a fixed establishment in the context of a parent utilising (exclusively) the toll manufacturing services of a subsidiary in Cabot Plastics Belgium v Belgium (Case C-232/22). The court has held that the mere fact that the subsidiary provides its services exclusively to its parent does not mean that the subsidiary will amount to a fixed establishment of the parent for VAT purposes.
Cabot Plastics Belgium (Cabot Belgium) provided toll manufacturing services to its parent company Cabot Switzerland established in Switzerland. Toll manufacturing involves in essence the provision of manufacturing and production services to materials or semi-finished products provided by the customer.
Pursuant to the toll manufacturing agreement...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
