32In that regard, while it is possible that a subsidiary constitutes the fixed establishment of its parent company (see, to that effect, judgment of 20 February 1997, DFDS, C‑260/95, EU:C:1997:77, paragraphs 25 and 26), such treatment depends on the substantive conditions set out in Implementing Regulation No 282/2011, in particular in Article 11 thereof, which must be assessed in the light of economic and commercial realities.
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