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An Irish company has requested a ruling on whether its import, logistics, and distribution activities in Spain, conducted via warehouses leased to a subsidiary, constitute a permanent establishment. The DGT indicates that if these activities are an essential part of the business model and are under the company's control, they could give rise to a permanent establishment.
Cuestión planteada
Para determinar si existe establecimiento permanente, se debe analizar si las actividades en España son meramente preparatorias o si constituyen una parte esencial y significativa de la empresa. Si la actividad logística integrada (almacenaje, despacho aduanero, picking, etc.) es parte del ciclo mercantil y está bajo la dirección y riesgo de la matriz, podría existir un establecimiento permanente. La conclusión definitiva requiere un análisis de hecho sobre las funciones, activos y personal para verificar si existe una estructura con coherencia económica y geográfica.
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