37As regards the fact that the taxable person providing the services undertakes contractually to use its equipment and its staff exclusively to provide the services concerned, it is apparent from the case-law of the Court that a legal person, even if it has only one customer, is assumed to use the technical and human resources at its disposal for its own needs. It is therefore only if it were established that, by reason of the applicable contractual provisions, a company receiving services had the resources of its service provider at its disposal as if they were its own that it could be regarded as having a suitable structure with a sufficient degree of permanence, in terms of human and technical resources, in the Member State where its service provider has established its business (see, to that effect, judgment of 7 April 2022, Berlin Chemie A. Menarini, C‑333/20, EU:C:2022:291, paragraph 48).
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