As expected, the decision has been aligned with the ruling of the Court of Justice of 11 March 2021, C-812/19 (Danske Bank). For example, services between a head office and a permanent establishment fall within the scope of VAT from the date of entry into force if one of the two establishments is part of a fiscal unity in a Member State of the European Union. If both branches are not part of a fiscal unity, the “old” principle of the ECJ FCE Bank will continue to apply and services between the various branches will fall outside the scope of VAT.
Source Deloitte
