EU · Treaty · Substance
Stronger beneficial ownership review when applying tax treaties
The application of treaty benefits in the EU is becoming more formalised.
The mere existence of a holding company is no longer sufficient grounds
for using double tax treaties.
In practice, this means the need to document the economic
logic, management functions and actual decision-making.
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VAT · E-commerce · Fixed Establishment
Fixed establishment when using European warehouses
The use of fulfilment centres in the EU may create VAT obligations
and structural consequences even where no company is registered.
The issue is not only VAT registration,
but also the analysis of substance and functions.
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Banking · Governance · KYC
Banks are strengthening their analysis of group management control
When opening accounts, banks analyse not only the ownership structure,
but also the actual allocation of management functions.
Formal board minutes are becoming insufficient —
consistency between the structure, tax logic and governance is required.
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