Skip to content

Transfer pricing policies that protect your group

Transfer pricing policies and documentation that protect your group against audits and double taxation.

The challenge

Transfer pricing is one of the highest-risk tax areas for corporate groups. Tax authorities worldwide are intensifying audits in this field, and penalties for non-compliance can be devastating: multimillion-euro adjustments, double taxation, and penalties that impact both the bottom line and the group's reputation.

Our solution

We design robust transfer pricing policies compliant with OECD guidelines and Spanish regulations. We prepare mandatory documentation, conduct comparability analyses, and defend the adopted positions before tax authorities.

Process

How we work

1

Functional analysis

We identify and document the functions performed, assets employed, and risks assumed by each group entity in related-party transactions.

2

Benchmarking

We conduct comparability studies using international databases to determine the market price ranges applicable to each transaction type.

3

Documentation

We prepare the mandatory documentation: Master File, Local File, and Country-by-Country Report, meeting the formal requirements of each jurisdiction.

4

Defence & APAs

We defend policies before tax authorities during audit proceedings and negotiate Advance Pricing Agreements (APAs) to obtain upfront legal certainty.

Our transfer pricing team combines technical expertise with practical experience in audits and litigation. We do not merely prepare documentation: we design policies that reflect the economic reality of the group and withstand scrutiny from tax authorities.

FAQ

Frequently asked questions

When is transfer pricing documentation mandatory?
In Spain, documentation obligations apply to related-party transactions exceeding certain thresholds (generally EUR 250,000 per transaction type). For groups with turnover above EUR 45 million, obligations expand significantly.
What are the penalties for non-compliance?
Penalties can reach 15% of the adjustment made by the tax authority, with minimums of EUR 1,000 per omitted data point or EUR 10,000 per data set. Moreover, a lack of documentation severely weakens the defensive position during an audit.
What is the arm's length principle?
It is the fundamental principle of transfer pricing: related-party transactions must be conducted under conditions equivalent to those that independent parties would agree to in comparable circumstances. All policies must satisfy this principle.
What are the OECD guidelines?
The Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations are the international benchmark standard. They define accepted valuation methods, documentation requirements, and dispute resolution procedures.
What documentation is required exactly?
The complete package includes: Master File (group information), Local File (each entity's related-party transactions), and Country-by-Country Report (for groups with turnover above EUR 750 million). Documentation must be prepared before the year-end close.
What is an APA and when is it advisable?
An Advance Pricing Agreement (APA) is a binding agreement with the tax authority on the valuation method applicable to related-party transactions. It is advisable when transactions are recurrent, of significant value, or difficult to benchmark.
What happens in case of double taxation from transfer pricing adjustments?
If a tax authority adjusts transfer prices, double taxation may arise. Mechanisms to resolve it include Mutual Agreement Procedures (MAP) under double taxation treaties and the EU Arbitration Convention.

Request a personalized consultation

Our experts are ready to analyze your situation and provide tailored solutions.

Free consultation