OrbitaxTreaty between Spain and Ireland – Spanish Administrative Tribunal considers commission agent acting in his own name as PE
|Treaty Development|Ireland; Spain
Spain's Tribunal Económico-Administrativo Central gave its resolution on 15 March 2012 (No. 00/2107/2007), published in June 2012, in a case relating to a multinational group involved in the design, development and manufacture of computer products which are commercialized through entities of the group. Details of the resolution are summarized below.
(a) Facts. An Irish company, without hu…
