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V2529-15 2 September 2015 · SG de Fiscalidad Internacional Criterion in force
OTRO · establecimiento permanente

A vessel may constitute a permanent establishment if it constitutes a fixed place of business in a specific geographical location

A Spanish shipping company inquires whether its vessel abroad may be considered a permanent establishment. The DGT indicates that it will depend on domestic regulations or the applicable treaty, but under the OECD model, it requires a fixed place of business in a specific geographical location with a certain degree of permanence.

The question raised

Question posed: Whether the vessel may be considered a permanent establishment abroad.

Apply this to a real case

What is published here, applied to a company or a specific case. The first meeting is free.

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