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Spain - Supreme Court Decision: New Criterion for Deemed Permanent Establishment while Acting through a Subsidiary Company?

Country:
Spain
Author:
F. Carreño; R. (Rebeca) Rodríguez
Issue:
International Transfer Pricing Journal, 2012 (Volume 19), No 4
Published:
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.
 
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