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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 […]
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 […]
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 […]
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 […]
