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Profit distribution to the permanent base of a foreign group

The client manages a complex system which includes radar, calculation rooms, and satellites. These increase the precision of a global positioning satellite (GPS) signals, thus permitting their use in sectors with special security requirements.
In Spain, the group’s permanent base offers support services to the company it is a part of and performs transactions with other related parties.
An analysis of the permanent base’s significant people functions was performed in Spain. In this way, its EP was hypothesised to be that of an independent company and market-value profit distribution was performed through a division of functions, assets, and risks in said operations.

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