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A Swiss company inquires whether storing its products in a warehouse owned by a group company in Spain constitutes a permanent establishment. The DGT responds that there is no permanent establishment if the company only receives a storage service, but warns that one could exist if an entity acts as an authorized agent to contract on its behalf.
Question raised: Existence of a permanent establishment of the inquirer in the Spanish territory to which the Tax applies.
The mere storage of products in a third party's warehouse does not imply the existence of a permanent establishment, unless the inquirer holds the warehouse as owner, holder of a real right, or lessee. For a permanent establishment to exist, a structure with human and technical resources with a sufficient degree of permanence is required. Likewise, an entity could be considered a permanent establishment if it acts as an authorized agency or representation to negotiate and contract in the name and on behalf of the inquirer.
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