
Specific transfer pricing documentation in Spain
The information contained in the documentation to be made available to the taxpayer in the event of a request from the Tax Agency, varies depending on the net turnover of the companies.
The information contained in the documentation to be made available to the taxpayer in the event of a request from the Tax Agency, varies depending on the net turnover of the companies.
On 21 March 2018, the European Commission put forward a proposal for a Community Directive to regulate the taxation of companies with a significant digital presence and adapt the concept of Permanent Establishment to the Digital sphere (Digital Permanent Establishment).
When a directly owned enterprise has the status of holding company according to the exemption scheme to avoid double taxation, the income from which dividends in Spain are distributed must meet the “minimum tax” requirement.
The latest regulatory and technical modifications for the keeping of VAT record books will become effective on 1 July 2018. These modifications are published under Order HFP/187/2018, of 22 February, whereby it is intended to finalise details and correct the errors that have been coming to light in the SII in Spain since it entered into force on 1 July 2017.
Although the OECD considers transaction-based methods as the most straightforward methods to determine whether or not business relationships between related entities comply with the arm’s length principle, we will use one or the other depending on the type of transaction to be examined.
The increasing globalization and the presence of more and more companies in different countries forces us to know if our company is complying with the regulations established in the Spanish Corporate Tax Law (LIS) regarding Transfer Pricing in Spain.