The Court of Justice of the European Union (ECJ) ruled in the Titanium case (C‑931/19) that own staff is required for a (sales) VAT fixed establishment (FE) to be present in an EU Member State (EU MS). In this case, the Court specified that when the owner of an immovable property in a EU MS, uses that property for a letting activity without making use of its own local staff, that activity does not constitute a FE.
Source Tiberghien