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A Spanish company asks whether replacing a distribution agreement with a commission agreement with its German parent creates a permanent establishment for the latter. The DGT responds that the subsidiary, being subject to detailed instructions and binding contracts, constitutes a permanent establishment in Spain.
Question raised
The Spanish subsidiary could be a dependent agent if it is subject to detailed instructions and its contracts bind the parent company, which would constitute a permanent establishment in Spain. In that case, the profits attributable to said establishment will be taxed under the Non-Resident Income Tax. Regarding VAT, the parent company is the taxable person in assimilated intra-Community acquisitions, whereas the subsidiary is the taxable person for supplies between the parent and the subsidiary, and for sales to the end customer.
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