The French Tax Authorities (“FTA”) have just published comments clarifying their position with respect to recent case law governing the fate of flows between the branches (branch or head office) of a single legal entity, which are also members of a VAT group in the State in which they are established. The FTA considers international supplies of services between these branches (branch or head office) as taxable for VAT.
- France – Tax Authorities Update Guidelines on VAT Treatment of Operations between Head Office and Branches
- BNP Paribas FE case in France
- C-812/19 (Danske Bank) – Judgment – Head Office part of VAT group & its Branch are separate taxable persons
- C-7/13 (Skandia) – Judgment – Supply of services between head office and branch part of VAT group constitutes a taxable transaction
- Focus on Supplies of services between Head Office and its Branch, whereby one of the parties is part of a VAT Group