“Tolling manufacturer = VAT FE of principal?” Belgian Court of Appeal refers to ECJ!

On 18 March 2022, the Belgian Court of Appeal of Liège referred preliminary questions to the European Court of Justice (“ECJ”) in a case where the Belgian tax authorities claim the existence of a Belgian VAT fixed establishment (“VAT FE”) for a Swiss principal, through its affiliated Belgian toll manufacturer. Will the ECJ finally stop the authorities’ hunt?

Source EY

See also

• ECJ C-333/20 (Berlin Chemie A. Menarini SRL) – Question – Fixed establishment via affiliate?
• ECJ Cases on Fixed Establishments (Art. 44 & 45)

---

---