Comments on ECJ C-232/22: Toll manufacturer does not constitute VAT fixed establishment

The Court of Justice of the European Union (CJEU) today held that a toll manufacturer in Belgium did not constitute a value added tax (VAT) “fixed establishment” for its affiliated Swiss principal.The CJEU’s judgment is in line with its earlier judgment in Berlin Chemie C-333/20 (7 April 2022).

Source: kpmg.com

See also

• ECJ C-232/22 (Cabot Plastics Belgium) – Judgment – Toll manufacturing with ancillary services does not lead to Fixed Establishment
• Summary of ECJ-232/22 (Cabot) – No fixed establishment due to lack of human and technical resources even if ancillary services are performed, exclusivity

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