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Tax & legal glossary

Transfer Pricing in Spain (Precios de Transferencia)

Transfer pricing (precios de transferencia) in Spain refers to the prices set in transactions between related parties — group companies, shareholder and company, director and company — which must comply with the arm's length principle under Art. 18 of the Corporate Income Tax Act (LIS, Ley 27/2014). Spanish law, fully aligned with OECD Transfer Pricing Guidelines, requires that such transactions be valued as if carried out between independent parties and that the pricing methodology be documented in a compliant master file and local file.

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What Is Transfer Pricing in Spain?

Transfer pricing (precios de transferencia) refers to the consideration agreed in economic transactions between related parties or associated persons — for example:

  • A foreign parent company and its Spanish subsidiary
  • A shareholder (holding ≥25%) and their Spanish company
  • Sister companies within the same group
  • A director and the company they manage

The central principle is the arm’s length standard (principio de libre concurrencia), codified in Art. 18 of Ley 27/2014 del Impuesto sobre Sociedades (LIS). It requires that agreed prices correspond to those that independent third parties would have agreed under comparable conditions. Spanish law is fully aligned with the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.

Transactions Covered

All economic transactions between related parties fall within the regime:

Transaction typeExamples
GoodsSales of products within the group
ServicesManagement fees, IT services, accounting
IntangiblesLicences, brand rights, patents, software licences
FinancingIntercompany loans, cash pooling
Asset transfersSales of shareholdings, real estate, IP

Documentation Requirements

TriggerObligation
Related-party transactions > €250,000/year (per counterpart)Master File + Local File
Consolidated turnover > €750M/year+ Country-by-Country Report (Modelo 231)
All related-party transactionsDeclaration in the corporate tax return (Modelo 200, Schedule)

The Master File contains information on the group structure, value chain, and internal allocation of functions and risks. The Local File documents each specific transaction: nature, parties, methodology applied, benchmarking analysis, and results achieved.

Valuation Methods

Primary methods (Art. 18(4) LIS, preferred):

  1. CUP (Comparable Uncontrolled Price): comparison with market prices in comparable arm’s length transactions
  2. Resale Price Method (RPM): resale price to third party less market gross margin
  3. Cost Plus Method (CPM): supplier cost plus market profit mark-up

Supplementary methods (subsidiary): 4. TNMM (Transactional Net Margin Method): net margin of the controlled transaction compared to net margin ranges of comparable companies 5. Profit Split: total profit allocated on an economically justifiable basis

Practical Example

A UK holding company charges its Spanish operating subsidiary (S.L.) an annual fee of €1.5M for the right to use a software platform.

AEAT review steps:

  1. Functional and risk analysis: Does the Spanish S.L. actually bear development risk, or is the UK holding the functional owner of the IP? If the S.L. is merely a “routine service provider” without significant risks, a high royalty rate is difficult to justify.
  2. Method selection: For a licence on established IP, the CUP method (comparison with market licence rates) is preferred where comparable licence transactions exist.
  3. Benchmarking: The agreed rate (€1.5M) must fall within the interquartile range of comparable licence agreements.
  4. Documentation: Local File with full transaction description and benchmarking analysis.

Advance Pricing Agreements (APV — Acuerdo Previo de Valoración)

An APV is a binding agreement with the AEAT that fixes in advance the applicable method and the accepted market price for future related-party transactions, with validity of up to 4 years. APVs are recommended for material, recurring, and complex transactions — royalties, intercompany financing of large amounts — as they provide full legal certainty and eliminate audit exposure on those transactions.

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Frequently asked questions

From what transaction volume do documentation requirements apply in Spain?
Companies with related-party transactions exceeding €250,000 per year with a single counterpart must maintain a documentation package (OECD-standard Master File and Local File). Groups with consolidated turnover above €750M must also file a Country-by-Country Report (CbCR, Spanish form Modelo 231).
What penalties apply for missing or deficient transfer pricing documentation in Spain?
Penalties range from 15% (documentation exists but is deficient) to 25% (no documentation at all) of the difference between the declared value and the market value determined by the AEAT, with minimum amounts of €3,000 or €15,000 per violation. In addition, the AEAT can make a bilateral adjustment to the corporate income tax base.
Which transfer pricing methods does the AEAT recognise?
Primary methods (preferred): Comparable Uncontrolled Price (CUP), Resale Price Method (RPM), and Cost Plus Method (CPM). Supplementary methods: Transactional Net Margin Method (TNMM, most common for services) and Profit Split Method. The choice of method must be documented and justified.
What is an Acuerdo Previo de Valoración (APV) and when is it advisable?
An APV is a binding advance pricing agreement with the AEAT on the transfer pricing method and acceptable price range for future transactions, valid for up to 4 years. It is advisable for substantial, recurring, and complex transactions (e.g. licences, intercompany loans) as it provides full legal certainty and eliminates audit risk on those transactions.
Which intercompany transactions carry the highest AEAT audit risk?
Transactions under closest scrutiny include: royalty and licence payments for intangible assets (brands, patents, software), intercompany loans with atypical interest rates, management fees without substantiable service delivery, and any transactions with entities in low-tax jurisdictions or formal tax havens (paraísos fiscales).

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