Spain - Supreme Court Decision: New Criterion for Deemed Permanent Establishment while Acting through a Subsidiary Company?
- F. Carreño; R. (Rebeca) Rodríguez
- International Transfer Pricing Journal, 2012 (Volume 19), No 4
- 28 June 2012
The authors analyse a recent decision of the Spanish Supreme Court on the deemed existence of a permanent establishment based on the activities of a dependent agent. Particular attention is given to the potential impact on permanent establishment issues for companies doing business in Spain through a subsidiary.