Ministerio de Hacienda / Ministry of Finance. SPAIN
PROBLEMS OF E-COMMERCE TAXATION. Direct Taxation
Legal and practical jurisdiction over the party liable for the tax
Difficulties of application of classical rules to avoid double taxation (principles of the origin, and source)
Determining nationality and tax residence
Crisis of the idea of Permanent Establishment. Alternatives
Allocation of Income to Permanent Establishments operating in a country
Transfer Prices
Specification of taxable income
Treatment of royalties