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Published in Newsletters, Transfer pricing news
On 11 February 2020, the OECD published the new Transfer Pricing Guidelines on Financial Transactions. This publication represents a substantial advance on the initiatives carried out in 2015, following the publication of the Reports on Actions 4 and 8-10 of the BEPS project, as well as the draft for public discussion launched on 3 July […]
Published in Transfer pricing news
On 21 January 2020 the General Directorate of the Spain’s Tax Administration Agency approved the general guidelines of the 2020 Tax and Customs Control Programme. Below we present the main measures of interest in the transfer pricing area. AUDIT PROGRAMME FOR COMPANIES REPORTING RECURRING LOSSES An important novelty of the 2020 Tax Audit Programme consists […]
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 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 […]
