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V1078-20 ·27 April 2020 ·consulta-vinculante Medium impact
Tax

No permanent establishment if no human or technical resources available

A non-resident with tourist rental properties asks whether a permanent establishment exists and whether the passive investor rule applies. The DGT states that no permanent establishment exists if there are no human or technical resources, own or subcontracted, for the activity.

In 6 key points

Lifecycle

2020-04-27PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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