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V1233-23 ·10 May 2023 ·consulta-vinculante Medium impact
Tax

Use of third-party warehouses, contract manufacturing or remote work does not alone establish a permanent establishment

A UK company asks whether its contract manufacturing, use of third-party warehouses and four remote workers in Spain constitute a permanent establishment. The DGT states that, under the described facts, no permanent establishment appears to exist, although it warns that a joint assessment of the actual operations is required.

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2023-05-10PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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