Global transactions

Fixed establishment and actual service recipient

Why group address and VAT ID do not always identify the tax recipient.

Updated: 2026-07-11 Rule version: tax-knowledge-2026.07 Valid from: 2026-07-11
GlobalEU B2B business ServicesDigital services

A fixed establishment can change the relevant recipient for certain services when it has sufficient human and technical resources and actually receives or uses the service. A postal address alone is not enough.

Facts to check

Contracting party, requester, user, cost centre, people, technical resources, place and payment flow should be considered together.

Group scenarios

Central procurement and local use can differ. Intercompany recharges do not replace analysis of the original supply.

Dynafis

Conflicting VAT ID, address and usage block recipient classification until confirmed by a reviewer.

Official references

Sources support traceability; national implementation and the individual case still require review.

fixed establishmentrecipientregistration
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