Jeremy Woolf a barrister at Pump Court Tax Chambers considers the various ramifications of cross-border supplies to branches
The European Court in Case C-210/04 Ministero dell' Economia e delle Finanze v FEC Bank plc[2007] STC 165 decided that no supply of services was made by the London head office of the FCE Bank when it provided management consultancy and data processing services to its Italian branch. The Italian authorities sought to impose a reverse VAT charge on the services on the basis that they were a supply from the London head office. Because the branch and head office were part of one company the Court considered that they could not be regarded as independent entities and the necessary legal relationship for a supply did not exist.
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Jeremy Woolf a barrister at Pump Court Tax Chambers considers the various ramifications of cross-border supplies to branches
The European Court in Case C-210/04 Ministero dell' Economia e delle Finanze v FEC Bank plc[2007] STC 165 decided that no supply of services was made by the London head office of the FCE Bank when it provided management consultancy and data processing services to its Italian branch. The Italian authorities sought to impose a reverse VAT charge on the services on the basis that they were a supply from the London head office. Because the branch and head office were part of one company the Court considered that they could not be regarded as independent entities and the necessary legal relationship for a supply did not exist.
...
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