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The Spanish Supreme Court approach on Subsidiary as a Permanent Establishment: the Roche Vitamins Europe Case

icon 23 de febrero, 2012
The Supreme Court in a business restructuring case upheld the position of the tax administration considering that a formal offshore relocation of functions does not constitute a valid route for avoiding the taxation of the profits sourced in Spain.
On January 12, 2011, the Spanish Supreme Court issued its long-awaited decision on the Roche Vitamins Europe case, where it ruled that the Spanish subsidiary of Roche Vitamins constituted an agency permanent establishment (PE) of Roche Vitamins Europe, a group company located in Switzerland.

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Autor/es

Eduardo Martínez-Matosas – Socio

José Manuel Calderón

Tipología

Análisis