Bad times for the «Permanent Establishment Hunters»: A subsidiary cannot be treated as a VAT fixed PE of its Foreign Parent Company

December 26, 2019

By: Antonio Barba de Alba

I have read many opinions of Advocate General Kokott over the past few years. And I have agreed with most of them, particularly her opinions on the «Danish cases,» which, inexplicably, the Court of Justice did not follow. For those interested in these cases, I wrote about them with my colleague Diego Arribas here and here. But I will start this post by repeating that Ms. Kokott’s comments on the lack of democratic legitimacy of the OECD recommendations should be taught in the first year of law studies throughout the European Union.


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