How the DGT's position has evolved
Current position
Transactions between related parties, including partners with a shareholding equal to or greater than 25%, must be valued at market value. For professional partner services, only the agreed value is admitted if the requirements of article 18.6 of the LIS (Corporate Income Tax Law) are met. Otherwise, it is mandatory to apply the valuation methods set out in section 4 of article 18 of the LIS.
The DGT's position remains constant in requiring the application of the arm's length principle through market value. The evolution shows greater precision by integrating and applying the specific requirements of article 18.6 of the LIS to determine when the agreed value is valid for professional partner services.
Turning points
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Introduces the distinction regarding the use of the agreed value in professional partner services, making it subject to compliance with the requirements of article 18.6 of the LIS.
Analysis based on 14 of 15 rulings with a stated position. Updated 26 September 2026.