11.9 Non-resident income tax payers (permanent establishments)
In the current regulation of the taxation of income obtained in Spain by taxpayers of the Non-Resident Income Tax through a permanent establishment, contained in the consolidated text of the Non-Resident Income Tax Law (LIRNR), approved by Royal Legislative Decree 5/2004, of March 5, the reference to the Corporate Tax Law is constant, so it has been considered convenient that the aforementioned taxpayers use the same declaration models as taxpayers of the Corporate Tax.
Furthermore, in accordance with the current regulations on the income attribution regime, entities under the income attribution regime established abroad with a presence in Spanish territory, that is, those that carry out an economic activity in said territory, have the status of taxpayers of the Non-Resident Income Tax, with the taxable base being the part of income obtained in Spanish territory that is attributable to the non-resident members of the entity.