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V2423-14 ·15 September 2014 ·consulta-vinculante Medium impact
Tax

Use of third-party facilities for unloading and storage does not constitute a permanent establishment

A Spanish company consulted whether a German company using its facilities for unloading and storing goods has a permanent establishment in Spain. The DGT concludes that providing unloading, storage, and transport services does not create a permanent establishment for the German company.

In 6 key points

How it affects those involved

The decision clarifies that the use of third-party premises for logistics activities does not establish a permanent presence for a foreign company in Spain.

Lifecycle

2014-09-15PublishedPublished 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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