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V1070-17 ·5 May 2017 ·consulta-vinculante Medium impact
FISCAL

It is possible and necessary to allocate central office expenses to a permanent establishment using a reasonable criterion

A French company with a branch in Spain asks whether it can re-claim advertising expenses from the central office to the permanent establishment. The DGT responds that such expenses must be allocated according to the principle of full competence and a reasonable criterion, although their final deductibility will depend on internal regulations.

In 6 key points

Lifecycle

2017-05-05PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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