VAT Newsletter 16/2025
Italy: update on the involvement of a fixed establishment in intra-Community supplies of goods
The Italian fixed establishment of a German headquarters was to be regarded as being significantly involved in a supply of goods by the German headquarters to an Italian customer. This was decided by the Italian tax authorities in a binding ruling in 2023. Very recently, the Italian tax authorities have had to rule again, in a similar case, and this time made a decisive distinction: The involvement of a fixed establishment in a supply of goods is to be ruled out if the fixed establishment merely renders supporting, administrative activities.
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