Head Office/Branch Relationships from the Perspective of Swiss VAT

In this article, which is derived from his presentation at the Forum of the Confédération Fiscale Européenne (CFE) on 23 April 2009, the author compares the Swiss “separate-entities” approach, under which services exchanged between businesses and their branches abroad are treated as taxable services, and the “single-entity” approach of the Court of Justice of the European Communities (ECJ), under which those services are treated as being outside the scope of VAT. He concludes that, from the perspective of the proper functioning of the VAT system, the ECJ’s approach has no real advantages.