Growing trend whereby a foreign parent company to have a fixed establishment in Belgium through its daughter company

The issue with parent-subsidiary VAT fixed establishment

The concept of VAT fixed establishment has recently been the source of litigation in several Member States. In those cases, tax authorities argue that a subsidiary is the VAT fixed establishment of its parent company.

In Belgium, we have seen this growing trend whereby the Belgian VAT authorities deem a foreign parent company to have a fixed establishment in Belgium through its daughter company, or more broadly in an intra-group context (specifically toll manufacturers and distributors).

Source PwC