We provide an overview of the latest state of affairs of the new tax qualification policy for (foreign) legal forms that will take effect as of January 1, 2025.
In essence, the Court of Justice ruled that the anti-profit shifting provision of Section 10a CITA 1969 is not contrary to the freedom of establishment.
The judgment offers welcome practical guidelines. Whether there is a building site for VAT purposes is of major practical importance and must always be assessed on a case-by-case basis.