Spanish rules on transfer pricing

Article Abstract:

Spain's tax laws do require that values in related-party transactions reflect the prices that would have been obtained in arm's-length transactions, but the laws do not expressly address transfer pricing. The laws were revised to address both under- and overvaluation. Tax auditors are not inclined to levy penalties against taxpayers found in violation of these transfer pricing regulations because of the uncertainty of the law and its application. Auditors have also been willing to consider justifications as to why price deviated from arm's-length.

Management, Taxation, Tax auditing, Tax audits, Related party transactions

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Spanish rules on transfer pricing

Article Abstract:

Transfer pricing laws in Spain have gone through a series of changes since 1991. The law in effect in 1996 looks at the overall taxpayer situation in determining proper pricing adjustments, a departure from the law during the period 1992-1995, under which bilateral adjustments were prohibited after the filing period. A series of case examples illustrates various approaches to dealing with cross-border transactions under Spanish law.

Administration of General Economic Programs, Regulation of Multi-Nationals, Multinational corporations, International trade regulation, international

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Spanish rules on transfer pricing

Article Abstract:

The author outlines discusses changes to Spanish income tax law with respect to transfer pricing. Topics include current rules on transfer pricing, advanced pricing agreements, transfer pricing adjustments, and international double taxation.

Public Finance Activities, International, Tax Administration, Spain, Methods, Tax planning

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