Insights

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

Transfer pricing in the Spain’s 2020 Tax Audit Programme

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 […]

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Newsletter 4/2019

Published in Newsletters

NEWSLETTER Issue 4/2019                                                                                                          […]

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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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