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V0242-23 ·14 February 2023 ·consulta-vinculante Medium impact
Tax

Office leasing by a non-resident does not constitute a permanent establishment if no own human or technical resources are used

A French company plans to acquire a building in Spain to lease it as offices through an external management company. The DGT ruled that no permanent establishment exists if the company does not use its own human and technical resources, and that the lessor is the taxable person for VAT purposes.

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2023-02-14PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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