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A natural person resident in a third country has enquired whether leasing a property in Spain for office use constitutes a permanent establishment. The DGT has determined that mere ownership of the property is insufficient if there are no human and material resources, whether owned or subcontracted, available to provide the leasing service.
Cuestión planteada Consideración del inmueble arrendado como establecimiento permanente del consultante en el territorio de aplicación del impuesto.
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