Allan Cinnamon (Cintax the Word Ltd) provides a quarterly update on tax treaty developments.
This article provides an update of the key tax treaty developments over the last few months.
Spanish commissionaire was PE of Irish principal
The Spanish National Appellate Court approved the prior decision of the Central Tax Tribunal in its decision C-182/2012 that a Spanish commissionaire agent constituted a permanent establishment (PE).
Following a business restructuring Dell Spain acted as a Spanish commissionaire for Dell Products (‘Dell Ireland’) for which it sold products in its own name. It also performed other services for Dell Ireland such as logistics marketing post-sales services and administering Dell Ireland’s online function. There was substantial commingling of the activities of the two companies. The Spanish company’s premises were at the...
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Allan Cinnamon (Cintax the Word Ltd) provides a quarterly update on tax treaty developments.
This article provides an update of the key tax treaty developments over the last few months.
Spanish commissionaire was PE of Irish principal
The Spanish National Appellate Court approved the prior decision of the Central Tax Tribunal in its decision C-182/2012 that a Spanish commissionaire agent constituted a permanent establishment (PE).
Following a business restructuring Dell Spain acted as a Spanish commissionaire for Dell Products (‘Dell Ireland’) for which it sold products in its own name. It also performed other services for Dell Ireland such as logistics marketing post-sales services and administering Dell Ireland’s online function. There was substantial commingling of the activities of the two companies. The Spanish company’s premises were at the...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
