Spain issues draft transfer pricing document regulations
November 01, 2007
José Luis Gonzalo, Ramón Palacín, Juan José Terraza, Carlos Gabarró, Eduardo Sánchez and Vanessa Hernández of Ernst & Young in Spain analyse the regulations take effect in 2008
The Spanish tax authorities have published draft regulations that develop the documentation requirements established under the recently enacted Spanish Tax Legislation on Transfer Pricing. The documentation requirements proposed by the Spanish tax authorities follow the EU Code of Conduct on transfer pricing that resulted from the EU Joint Transfer pricing Forum. In this sense, two separate sets of documents are required for a group of companies: (i) a Masterfile related to the whole group and applicable to all the entities, and (ii) specific information on the description, analysis and valuation of the controlled transactions carried out by the Spanish corporate taxpayer itself.

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