Insights

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

TAX AUDITS (IN TRANSFER PRICING) IN TIMES OF COVID-19

Published in Newsletters, Transfer pricing news

In February 1st, Spain’s Official Gazette published the general guidelines of the Tax and Customs Control Plan for the year 2021. Following the trend set by previous years, issues relating to the audit of related-party transactions and transfer pricing are gaining weight and forcefulness among the so-called “actions for the investigation and verification of tax […]

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Italy amends TP documentation requirements

Published in Newsletters, Transfer pricing news

On November 23, the Italian Revenue Agency issued new regulations on transfer pricing documentation, Act n. 360494, which introduces substantial and significant changes in the support of the application of the arm’s length principle and the Italian penalty-protection regime, and completely replaces Italy’s former transfer pricing regulations in Act no. 2010/137654. Scope of the reform […]

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Denmark may introduce mandatory filing of TP documention with the tax return

Published in Newsletters, Transfer pricing news

On October 8, coinciding with the beginning of the parliamentary year in Denmark, a draft bill was presented for debate that modifies the terms of presentation of transfer pricing documentation and the consequences of failure to present it. To date, as in most EU countries, the Danish transfer pricing rules require taxpayers to prepare transfer […]

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Spanish TP Reporting (form 232) must be filed in November

Published in Newsletters, Transfer pricing news

Spanish resident companies and permanent establishments in Spain with tax year ending 31 December 2019 must file the Tax Reporting (Form 232) on related-party transactions and transactions/investments in tax havens during the month of November 2020. For those taxpayers with a different tax year closing date, the filing period is the eleventh month after the […]

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Transfer Pricing in Times of COVID-19

Published in TPS, Transfer pricing news

Our founding partner Claire Sanga participated in the webinar organised by TaxLinked.net in colaboration with Pride Partners International.  Enjoy the video recording below and keep updated on the relevant issues you need to know for a TP-compliant closing of financial year 2020 and the actions you need to take on an urgently basis before year […]

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Asistencia en inspecciones fiscales

Spain’s Supreme Court confirms the criteria for applying transfer pricing penalties

Published in Newsletters, Transfer pricing news

On 18 May 2020, the Spain’s Supreme Court has ruled that the Tax Administration can apply the penalty regime provided for in the General Tax Law (GTL) in cases of transfer pricing adjustments to related-party transactions carried out by taxpayers who are exempt from the documentation requirements. This resolution confirms the interpretative criterion of the […]

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New transfer pricing requirements in Argentina

Published in Newsletters, Transfer pricing news

On May 15, the Federal Administration of Public Revenues (“AFIP”) published Resolution 4717/2020 regarding the transfer pricing regime (amended by R.G. 4733/2020 on June 4, 2020). This resolution establishes the new documentation requirements for related-party transactions, as well as the new deadlines extended due to the COVID19.  The main changes introduced by Resolution 4717/2020 are […]

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Transfer pricing and Coronavirus

Published in Newsletters, Transfer pricing news

As we are all gradually coming to terms with the fact that Coronavirus is a reality, many enterprises are having to deal with immediate operational issues and manage immediate cash-flow tensions, negotiating with employees, suppliers and financial institutions, amongst others.  Companies are focussing their efforts in putting into place measures in order to mitigate as […]

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