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V1480-14 ·4 June 2014 ·consulta-vinculante Medium impact
Tax

No permanent establishment for storage or intermediation activities

A Dutch company asks whether its trading and repurchase of raw materials in Spain, via third-party warehouses or a group subsidiary acting as intermediary, constitutes a permanent establishment. The DGT determines that no permanent establishment exists in the described cases.

In 6 key points

How it affects those involved

The ruling clarifies that storage or intermediary activities through third-party warehouses or a group subsidiary do not create a permanent establishment in Spain.

Lifecycle

2014-06-04PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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