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 the Court of Justice of the European Union (CJEU) in Dong Yang Electronics (Case C-547/18). With its ruling on 7 May 2020,…

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 to an individual resident in Thailand, for the purposes of Swiss federal and cantonal withholding taxes on pension benefits paid to…

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 (Poland) and concerning the existence of a VAT fixed establishment (FE) of a third-country (Korea) company in an EU Member State (Poland). As AG…