Secondary Establishments in EU VAT and Treaty Law

This article compares the concept of secondary establishment for direct and indirect tax purposes, as defined in the OECD Model (2014), the UN Model (2011) and the EU VAT Directive (2006/112). It also examines recent developments regarding the interpretation of the fixed establishment concept by the ECJ and possible modifications to the permanent establishment concept stemming from current discussions on the taxation of the digital economy.