54In accordance with well-established case-law in the area of VAT, the term fixed establishment implies a minimum degree of stability derived from the permanent presence of both the human and technical resources necessary for the provision of given services (Case 168/84 Berkholz [1985] ECR 2251, paragraph 18; DFDS, paragraph 20; Case C-190/95 ARO Lease [1997] ECR I-4383, paragraph 15). It thus requires a sufficient degree of permanence and a structure adequate, in terms of human and technical resources, to supply the services in question on an independent basis (ARO Lease, paragraph 16).
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