VAT grouping

CJEU, Double Taxation, DTA, Dual VAT, ECJ, Financial institutions, Financial services, Fixed establishment, Indirect taxation, International Tax Law, Pensions, Permanent Establishments, Physical presence, Place of Supply, Place of taxation, Tax Treaties, United Nations, VAT, VAT grouping

(Temple Tax Chambers; King’s College London)/ /Leave a comment
PVD article 44

Territorial connection (or its more fashionable name “nexus”) for tax purposes is expressed in a variety of ways in domestic and international legal instruments. Permanent establishment in article 5 of the Model treaties and “fixed base” in article 14 of the UN Model are central concepts in direct tax subject matter jurisdiction. Fixed establishment The…

CJEU, Cost-sharing exemption, VAT, VAT grouping

(Kristianstad University and Lund University)/ /Leave a comment

Introduction The first part of my reflections on case C-77/19 Kaplan International Colleges UK (further referred to as Kaplan) concerned the relationship between membership in a VAT group on the one hand and a cost-sharing group on the other. In this article, I will comment on the questions referred to the CJEU, which the Court…

CJEU, Cost-sharing exemption, VAT, VAT grouping

(Kristianstad University and Lund University)/ /Leave a comment

On 18 November 2020, the CJEU delivered its judgment in case C-77/19 Kaplan International Colleges UK[1] (I will further refer to it as Kaplan). The questions which had been referred by the UK national court in the case had raised hopes that the CJEU would provide important clarifications as to the geographical scope of application…