Fixed establishments and VAT-saving schemes

In the framework of cross-border transactions, fixed establishments play an independent role under the EU Sixth Directive, for example for the purpose of determining the place where intangible services are deemed to be supplied for VAT purposes. In particular the latter provision gives rise to VAT-saving schemes set up by taxable persons established in the EU that have no, or merely a limited, right to deduct input tax. In the article, the author describes various aspects of the schemes in question.