11.9 Non-resident income tax taxpayers (permanent establishments)
In the current regulation of the taxation of income obtained in Spain by non-resident Income Tax taxpayers through 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 for the aforementioned taxpayers to use the same declaration models as Corporate Tax taxpayers.
On the other hand, in accordance with the current regulation of the income attribution regime, entities under the income attribution regime incorporated abroad with a presence in Spanish territory, that is, those that develop an economic activity in said territory, have the character of non-resident Income Tax taxpayers, the tax base constituting the part of income obtained in Spanish territory that is attributable to the non-resident members of the entity.