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V0860-15 ·18 March 2015 ·consulta-vinculante Medium impact
Tax

No permanent establishment if sales promotion and marketing only

A Swiss entity asks whether its new operations in Spain, based on resident subsidiaries and marketing services, constitute a permanent establishment for VAT and IRNR. The DGT responds that no permanent establishment exists if agents lack the authority to negotiate or bind the entity.

In 6 key points

Lifecycle

2015-03-18PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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