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The Spanish substantialist approach to fragmented structures of business: the Dell Case, a subsidiary as Permanent Establishment
4 de septiembre, 2012
1. Introduction
On March 15, 2012, the Spanish Central Economic-Administrative Court (TEAC) delivered its ruling on the Spanish Dell case, concluding that the activities of the Spanish subsidiary of Dell (Dell Spain) constituted a permanent establishment (PE) of a group Irish sales company (Dell Products).
On March 15, 2012, the Spanish Central Economic-Administrative Court (TEAC) delivered its ruling on the Spanish Dell case, concluding that the activities of the Spanish subsidiary of Dell (Dell Spain) constituted a permanent establishment (PE) of a group Irish sales company (Dell Products).
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