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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 Newsletters, 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 […]
Published in Transfer pricing news
On 13 February 2019, the OECD released a consultation document “Addressing the Tax Challenges of the Digitalization of the Economy”, which follows a policy note issued on 29 January 2019. A significant number of interested parties placed their comments on the discussion document by 6 March, as well as participated in the public consultation meetings […]
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.), […]
Published in Newsletters
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, […]
Published in Newsletters
Spanish Supreme Court rules on tax penalties applicable to TP reassessments in transactions exempt from documentation requirements On 15 October, Spanish Supreme Court ruled that the specific transfer pricing penalty regime – including the penalty protection provision when the taxpayer prepares complete contemporaneous documentation – is only applicable to the related-party transactions […]
Published in Newsletters
<!doctype html> The Filing period for Transfer Pricing Reporting (Form 232) is due in November Spanish resident companies and permanent establishments in Spain with tax year ending 31 December 2017 must file the Tax Reporting (Form 232) on related-party transactions and transactions/investments in tax havens during the month of November 2018. For those taxpayers […]
Published in Newsletters
In our July 2018 News Alert, we inform on the latest amendments to the OECD Guidelines on Intangible Assets and the Profit-Split Method, ongoing projects of the BEPS Inclusive Framework and the latest court rulings on transfer pricing OECD Revised Guidance on the Application of the Transactional Profit Split Method This past […]
Published in Transfer pricing news
On August 31st, Ministerial Order HFP/816/2017 of August 28th, 2007 has approved form 232 for the reporting of related-party transactions, operations and situations related to countries or territories classified as tax havens. For fiscal years beginning on or after January 1st, 2016, Spanish resident companies and permanent establishments located in Spain should report, using the […]