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A Spanish management company has requested a ruling on whether managing Luxembourgish alternative investment funds (AIFs) from Spain renders these funds tax residents or creates a permanent establishment. The DGT has ruled that the management company's activity is independent and does not imply that the funds have their place of effective management in Spain or a permanent establishment.
Question raised 1. Whether the cross-border management of entities L1 and L2 carried out from Spanish territory may result in their being considered tax residents in Spain for Corporate Income Tax purposes.
La gestión profesionalizada de un FIA por una sociedad gestora no implica que el fondo tenga su sede de dirección efectiva en España, ya que la actividad de la gestora es distinta a la mera tenencia de aportaciones del fondo. Asimismo, la gestora no actúa como establecimiento permanente de los fondos al realizar una actividad propia y diferenciada. Para que el arrendamiento de inmuebles por parte de un FIA sea actividad económica, este debe disponer de personal propio con contrato laboral a jornada completa, no siendo relevante que la gestora sí disponga de medios humanos.
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