Spain - Oil and Gas Operational Structure Based on Joint Operation Agreements Gives Rise to Multiple Permanent Establishments within a Single Country
- R. Bernales; L.F. Kosters
- European Taxation, 2015 (Volume 55), No 10
- 11 September 2015
On 22 January 2014, the Spanish tax authorities issued a tax ruling regarding the application of the exemption method to avoid double taxation of profits attributable to permanent establishments. The ruling makes it clear that a Spanish resident company may have multiple permanent establishments in a foreign country. This note discusses the ruling issued by the Spanish authorities, as well as the consequences thereof.