When the permanent establishment concretely intervenes in the operations, performing a qualitatively qualifying role and operating with a significant degree of autonomy from the
parent company, then – on the basis of art. 192-bis of the VAT directive, which speaks of “participation” in the operation by the building – we can agree with the conclusion reached
by the Revenue Agency in its response to question no. 57 of 2023: in this case it is necessary to operate with a double VAT transaction, intra-EU between the registered office
Sources:
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