Supreme Court considered that Spanish subsidiary of Swiss entity was permanent establishment

The nonresident entity was using the factory, warehouse, and premises of the Spanish subsidiary and was even providing instructions to the subsidiary’s employees. In addition, the Swiss entity assumed all the risks. The court concluded that the Spanish subsidiary was a permanent establishment in Spain for VAT purposes and was required to charge Spanish VAT on its sales in Spain.

Source: Deloitte

See also THIS post about this case.

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