Insights

In our Insights section, you can access our free publications, our regular newsletter and more information on transfer pricing and our firm

Newsletter 3/2019

Published in Newsletters

NEWSLETTER Issue 3/2019                                                                                                          […]

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Functional characterization and expense structure

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 […]

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The Spanish High Court clarifies the application of the interquartile range in the Transactional Net Margin Method

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 […]

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Newsletter 2/2019

Published in Newsletters

  NEWSLETTER Issue 2/2019                                                                                                        […]

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Spanish Tax Administration (STA) sends letters to SMEs with “anomalous” margins

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 […]

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Newsletter 1/2019

Published in Newsletters

  NEWSLETTER Issue 1/2019                                                                                                        […]

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Transfer pricing in the 2019 Spain’s Tax Audit Plan

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.), […]

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TP Alert – CbCr notification by year end

Published in Newsletters, Transfer pricing news

    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, […]

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