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Company taxation or taxation on an individual non-resident operating without PE is substantially different. Taxation is done for each individualised transaction. Net income without deducting any expenses whatsoever is computed, with the exception of economic activities that allow the deduction of certain staff expenses, the cost of materials and supplies.
It should be noted that the general rate of 24% is applicable to those amounts satisfied for the provision of management support services, paid by the Spanish sister company to its mother company, notwithstanding its consideration as corporate profits in the conventions to avoid double taxation.
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