Reference health
Secondary Establishments in EU VAT and Treaty Law
not checkable · checked 2026-08-19
This work could not be checked — none of the deposited references carry a DOI. No claim is made either way about its reference list.
29 without a DOI — not checked. A reference deposited without a DOI is never matched by title or guessed at; it stays outside the checked set, and this line discloses that.
The 29 references without a DOI — listed, not checked
no DOI — not checkedPhD, LLM, MSc; Manager of the Current Awareness and Tables (CAT) Knowledge Group, IBFD, and Managing Editor of the Bulletin for International Taxation. The author can be contacted at a.bal@ibfd.org.
no DOI — not checkedOECD Model Tax Convention on Income and on Capital (15 July 2014), Models IBFD.
no DOI — not checkedUN Model Tax Convention on Income and on Capital (1 Jan. 2011), Models IBFD.
no DOI — not checkedCouncil Directive 2006/112/EC of 28 November 2006 on the common system of value added tax, OJ L 347 (2006), EU Law IBFD.
no DOI — not checkedOECD Draft Tax Convention on Income and on Capital (30 July 1963), Models IBFD.
no DOI — not checkedOECD Model Tax Convention on Income and on Capital: Commentary on Article 5 para. 4 (15 July 2014), Models IBFD.
no DOI — not checkedPara. 4.2-4.5 OECD Model: Commentary on Article 5 (2014).
no DOI — not checkedPara. 5 and 6 OECD Model: Commentary on Article 5 (2014).
no DOI — not checkedPara. 6 OECD Model: Commentary on Article 5 (2014).
no DOI — not checkedPara. 10 OECD Model: Commentary on Article 5 (2014).
no DOI — not checkedA person who is authorized to negotiate all elements and details of a contract in a way that binds the enterprise can be considered to exercise his authority to conclude contracts even if the contract is signed by another person in the state in which the enterprise is resident.
no DOI — not checkedCouncil Directive 2011/96/EU of 30 November 2011 on the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States, OJ L 345, 29 Dec. 2011, EU Law IBFD.
no DOI — not checkedCouncil Directive 2003/49/EC of 3 June 2003 on a Common System of Taxation Applicable to Interest and Royalty Payments Made Between Companies of Different Member States, OJ L157 (2003), EU Law IBFD.
no DOI — not checkedCouncil Directive 2009/133/EC of 19 October 2009 on the common system of taxation applicable to mergers, divisions, partial divisions, transfers of assets and exchanges of shares concerning companies of different member states and to the transfer of the registered office of an SE or SCE between member states (codified version), EU Law IBFD.
no DOI — not checkedFor example, the term “fixed establishment” is relevant to determine the place of supply of electricity, gas, heat and cooling energy (which are considered goods for EU VAT purposes) under article 39 of the VAT Directive (2006/112).
no DOI — not checkedIT: ECJ, 23 Mar. 2006, Case C-210/04 , Ministero dell’Economia e delle Finanze (Ministry of Economic Affairs and Finance) and Agenzia delle Entrate (Revenue Agency) v. FCE Bank plc, para. 39, ECJ Case Law IBFD.
no DOI — not checkedSixth Council Directive 77/388/EEC of 17 May 1977 on the harmonization of the laws of the Member States relating to turnover taxes – Common system of VAT: uniform basis of assessment, OJ L145 (1977), EU Law IBFD.
no DOI — not checkedE2: ECJ, 4 July 1985, Case 168/84, Gunter Berkholz v. Finanzamt Hamburg-Mitte-Altstadt, ECJ Case Law IBFD.
no DOI — not checkedE2: ECJ, 17 July 1997, Case C-190/95, ARO Lease BV v. Inspecteur van de Belastingdienst Grote Ondernemingen te Amsterdam, ECJ Case Law IBFD.
no DOI — not checkedDE: ECJ, 28 June 2007, Case C-73/06, Planzer Luxembourg Sàrl v. Bundeszentralamt für Steuern, ECJ Case Law IBFD.
no DOI — not checkedE2: ECJ, 20 Feb. 1997, Case C-260/95, Commissioners of Customs and Excise v. DFDS A/S, ECJ Case Law IBFD.
no DOI — not checkedCouncil Implementing Regulation 1042/2013 of 15 March 2011 laying down implementing measures for Directive 2006/112/EC on the common system of value added tax, OJ L77/1 (2011) (as subsequently amended), EU Law IBFD.
no DOI — not checkedPara. 6 OECD Model: Commentary on Article 5 (2014).
no DOI — not checkedArt. 47 VAT Directive (2006/112).
no DOI — not checkedPL: ECJ, 16 Oct. 2014, Case C-605/12, Welmory sp. z o.o. v. Dyrektor Izby Skarbowej w Gdańsku, ECJ Case Law IBFD.
no DOI — not checkedP. Collin & N. Colin, Task Force on Taxation of the Digital Economy (Jan. 2013), available at www.hldataprotection.com/files/2013/06/Taxation_Digital_Economy.pdf.
no DOI — not checkedOECD, Action Plan on Base Erosion and Profit Shifting (2013), International Organizations' Documentation IBFD, also available at www.oecd.org/ctp/BEPSActionPlan.pdf.
no DOI — not checkedOECD, BEPS Action 1: Address the Tax Challenges of the Digital Economy (Public Discussion Draft) para. 59 (2014), available at http://www.oecd.org/ctp/tax-challenges-digital-economy-discussion-draft-march-2014.pdf.
no DOI — not checkedOECD Business Profits Technical Advisory Group (BP TAG), Attribution of Profits to a Permanent Establishment Involved in Electronic Commerce Transactions (Feb. 2001).
What this badge says. CiteStamped means the CHECKABLE references of this
work were clean at the dated check: each resolved to a known work in a public registry, and none
carried a retraction notice at that time. It says nothing about the quality, findings,
or importance of the work itself, and nothing about references deposited without a DOI.
checked 2026-08-19 — re-checked daily as this page is visited; titles and statuses come from Crossref and DataCite and are not part of the signed record
Embed this badge
Both snippets point at the live badge image and link back to this page. The badge re-renders from the daily check, so an embed never goes stale by more than a day of visits.
<a href="https://citestamp.com/citestamped/10.59403/ppefc"><img src="https://citestamp.com/citestamped/10.59403/ppefc/badge.svg" alt="CiteStamped reference-health badge" width="460" height="64"></a>
[](https://citestamp.com/citestamped/10.59403/ppefc)