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V0306-14 10 February 2014 · SG de Fiscalidad Internacional Criterion in force
IRNR · establecimiento permanente

No permanent establishment for a UK LLP carrying out marketing activities in Spain

A UK limited liability partnership with an office in Spain for marketing and sales seeks to know whether it has a permanent establishment for IRPF and VAT purposes. The DGT determines that no permanent establishment exists for its members if the activities are preparatory or auxiliary and lack the power to enter into contracts.

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