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V3250-15 ·23 October 2015 ·consulta-vinculante Medium impact
FISCAL

Spanish intermediary fees not subject to retention in Colombia without permanent establishment

A Spanish company will provide intermediary services to a Colombian entity from Spain. The DGT states that, due to the absence of a permanent establishment in Colombia, profits are only taxable in Spain under the double taxation treaty.

In 6 key points

Lifecycle

2015-10-23PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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