Rocio Herrera Molina

Rocio has twelve years of experience in international taxation, specialising in transfer pricing since 2016. She joined BMC in 2020, where she manages transfer pricing documentation and benchmarking studies for multinational groups operating in Spain.

Her work covers the full documentation cycle — from the Master File and Local Files required under Spanish regulations to filing APA applications before the AEAT and coordinating Mutual Agreement Procedure (MAP) proceedings with foreign tax authorities. Before joining BMC, she worked in the transfer pricing team of a leading international law firm, where she contributed to projects across pharmaceutical, technology, and organised retail sectors.

Rocio applies a rigorous approach to both the economic analysis of related-party transactions and the defence of adopted positions in the event of a tax inspection. Her command of the OECD Transfer Pricing Guidelines and BEPS measures allows her to identify risk points in each group’s TP policy at an early stage and propose documentation-robust solutions that withstand administrative scrutiny.