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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.
Cuestión planteada 1. Si la consultante tiene un establecimiento permanente en Colombia si articula su inversión a través de un PAC.
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