background image
5.4. Tax Base for Non-Resident Entities

Non-resident entities are liable to tax in Spain only in respect of income deemed to arise in Spain. If income is derived in Spain through a permanent establishment, the non-resident entity is taxed almost in the same way as Spanish resident entities, with the specificities mentioned in Sec. 4.2. When income is not obtained through a permanent establishment, the non-resident entity is generally taxed on the gross income obtained in Spain (except for EU resident companies, which, following several decisions by the ECJ, are allowed to deduct related expenses).