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Published in Transfer pricing news
The Spanish Tax Administration has published the guidelines for the tax audit plan for 2019, and the actions affecting the transfer prices of multinational groups will be particularly affected by the practical implementation of the measures approved in the OECD’s BEPS Project. The exchange of tax information (Country by Country Report, aggressive tax planning, etc.), […]
Published in Newsletters
REMINDER: Spanish resident companies should notice CbCr reporting entity to the Tax Administration before year end Spanish resident subsidiaries belonging to Multinational Groups obliged to file the Country-by-Country Report must notice to the Spanish Tax Administration the identification data of the reporting entity. For companies whose fiscal year coincides with the calendar year, this means […]
Published in Newsletters
Spanish Supreme Court rules on tax penalties applicable to TP reassessments in transactions exempt from documentation requirements On 15 October, Spanish Supreme Court ruled that the specific transfer pricing penalty regime – including the penalty protection provision when the taxpayer prepares complete contemporaneous documentation – is only applicable to the related-party transactions subject to […]
Published in Newsletters
The Filing period for Transfer Pricing Reporting (Form 232) is due in November Spanish resident companies and permanent establishments in Spain with tax year ending 31 December 2017 must file the Tax Reporting (Form 232) on related-party transactions and transactions/investments in tax havens during the month of November 2018. For those taxpayers with a different tax […]
Published in Newsletters
In our July 2018 News Alert, we inform on the latest amendments to the OECD Guidelines on Intangible Assets and the Profit-Split Method, ongoing projects of the BEPS Inclusive Framework and the latest court rulings on transfer pricing OECD Revised Guidance on the Application of the Transactional Profit Split Method This past June 21st, […]
Published in Transfer pricing news
On August 31st, Ministerial Order HFP/816/2017 of August 28th, 2007 has approved form 232 for the reporting of related-party transactions, operations and situations related to countries or territories classified as tax havens. For fiscal years beginning on or after January 1st, 2016, Spanish resident companies and permanent establishments located in Spain should report, using the […]
Published in TPS
The Official Gazette publishes the Ministry’s Order approving the Form 231 for Country by Country Reporting. This tax form must be filed by Spanish-resident ultimate parent company or designated entities for groups with a consolidated turnover amounting to at least 750 million euros. The filing period starts at the year-end of the parent company and […]
Published in TPS
Transfer Pricing Specialists (TPS) is recognized as a leading independent Transfer Pricing firm in Spain. Founded by professionals with many relevant years of experience doing business in the field, TPS is currently the main independent player in the country. This new alliance will help to meet the growing demand of multinationals for comprehensive transfer pricing […]
Published in Spanish TP rules, Transfer pricing news
Starting fiscal year 2016, new transfer pricing documentation requirements are applicable in Spain, since new Corporate Income Tax Regulations are adapted from the new OECD’s transfer pricing documentation package approved in the framework of the BEPS Project. These transfer pricing documentation requirements are applicable to both Spanish companies and branches or permanent establishments (PE’s) of foreign […]
Published in Transfer pricing news
In the framework of a far-reaching Tax Reform, a new Corporate Income Tax Law was passed and enacted by the Parliament, effective for the tax years beginning as of January 1st, 2015. The new legislation introduces some changes to the Spanish transfer pricing (TP) regulatory framework. Related-party definition: Direct shareholding threshold is increased from 5% […]