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A Spanish company seeking ETVE status asks whether a PAC investment in Colombia creates a permanent establishment. The DGT states that if a PAC carries out construction activities exceeding six months, it constitutes a permanent establishment, and the income may be exempt under the ETVE regime.
Question raised 1. Whether the taxpayer has a permanent establishment in Colombia if it structures its investment through a PAC.
If the PAC carries out an economic activity in Colombia through the organization of material and human resources, and this includes construction works with a duration exceeding six months, the taxpayer obtains profits through a permanent establishment. Under the Spain-Colombia Convention, these profits may qualify for the exemption under Article 22 of the LIS if the permanent establishment has been subject to a tax of an identical or analogous nature with a nominal rate of at least 10 percent. Likewise, the profit distribution regime of Article 108 of the LIS applies to ETVEs.
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