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

Journal
Carreño, F.; Rodríguez, R. (Rebeca)
Spain
International Transfer Pricing Journal 2012 (Volume 19), No. 4
PriceUSD 45

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.