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V0059-21 ·20 January 2021 ·consulta-vinculante Medium impact
Tax

Presence of a payment entity agent in Italy may constitute a permanent establishment

A Spanish payment entity asks whether its activities in Italy through an agent amount to having a permanent establishment. The DGT states that if the agent is a natural or legal person providing payment services on behalf of the entity, a permanent establishment exists under the double taxation treaty with Italy.

In 6 key points

Lifecycle

2021-01-20PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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