Skip to content
V2934-23 ·2 November 2023 ·consulta-vinculante Medium impact
Tax

Spanish subsidiary of foreign fund manager not constitutes permanent establishment

The DGT responds that fund management activities are independent of asset holding, so the subsidiary is not a permanent establishment of the fund.

In 6 key points

How it affects those involved

The absence of a permanent establishment means the fund is not subject to Spanish tax on management activities through the French subsidiary.

Lifecycle

2023-11-02PublishedPublished 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