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Published in Transfer pricing news
In transfer pricing projects, both for the preparation of annual documentation and for the definition of a transfer pricing policy or specific valuation criteria, one of the aspects that is most cryptic for clients is the so-called functional analysis or distribution of the functions exercised, assets employed and risks assumed by each of the group […]
Published in Transfer pricing news
The ruling of the Spanish High Court (“Audiencia Nacional”) nº 1072/2019, of 6 March, has pronounced on two relevant aspects in the practical application of the Transactional Net Margin Method (TNMM): The use of multi-year averages in both the comparable entities and the tested party; and The most suitable point in the interquartile range at […]
Published in Transfer pricing news
Profit Participating Loans enjoy a certain popularity thanks to their enormous flexibility and the advantages provided by their mercantile and accounting regulation in Spain. However, the recent National Court Decisions of 28 June 2018 and 1 February 2019 point to the variable remuneration of profit participating loans as a source of controversy with the Tax […]
Published in Newsletters, Transfer pricing news
According to the Europa Press news agency, the Spanish Tax Administration (STA) has launched for the third consecutive year a letter campaign aimed at small and medium-sized enterprises, in which it informs them of “inconsistencies” between the data declared by them and that collected from other sources of tax information. Among the “inconsistencies” highlighted are […]
Published in Transfer pricing news
On 13 February 2019, the OECD released a consultation document “Addressing the Tax Challenges of the Digitalization of the Economy”, which follows a policy note issued on 29 January 2019. A significant number of interested parties placed their comments on the discussion document by 6 March, as well as participated in the public consultation meetings […]
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, […]
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 […]