Skip to content
V2414-25 ·10 December 2025 ·consulta-vinculante Low impact
Tax

The existence of a permanent establishment through a construction site depends on whether its duration exceeds 12 months

The DGT clarifies that if a construction project lasts over 12 months, a permanent establishment will be deemed taxable under IRNR.

In 6 key points

How it affects those involved

Projects exceeding 12 months may trigger IRNR liability for Italian companies operating in Spain.

Lifecycle

2025-12-10PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

Does this provision affect you?

The tax team reviews your specific situation.

Talk to the tax team
This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
Email
Contact