Can a mooring point of a vessel be considered as a PE for VAT purposes? Judgment of the Economic-Administrative Court of October 23

The concept of Permanent Establishment (PE) for VAT is defined in the VAT Act through the article 69.Three, in its general concept as “any fixed place of business where entrepreneurs or professionals perform business or professional activities”. Under this definition and in accordance with the information requested and at the…

Leasing operations in the VAT and its qualification as provision of service or supply of goods. Judgment of ECJ of October 4, 2017

Traditionally there has been a problem in relation to leasing operations and their qualification for VAT purposes such as provision of services or delivery of goods, since that qualification will affect to the moment the VAT becomes due and payable, as from the moment of the supply of the goods,…

The profit split method in Transfer Pricing

The intra-group transactions must be valued according to the arm’s length principle, and that is very known. The problem lies on the selection of the appropriate transfer pricing method for each case. Obviously, the selection of the method depends on the type of transaction and the availability of the information…