The Spanish Position on the Concept of a Permanent Establishment: Anticipating BEPS, beyond BEPS or Simply a Wrong Interpretation of Article 5 of the OECD Model?

In this article, the author considers the Spanish position regarding the concept of a permanent establishment and whether the Spanish concept conforms to the OECD/G20 Base Erosion and Profit Shifting (BEPS) initiative or is simply an erroneous interpretation of the provisions of article 5 of the OECD Model.