In the current globalized environment, the number, the relevance and the typology of related transactions has increased, as well as the control that the Tax Authorities exercise over them. This represents a challenge for the taxpayer who requires solutions ranging from risk identification and policy planning to the preparation of transfer pricing documentation.
In this sense, the Spanish transfer price legislation regulates the obligation to prepare documentation on related-party transactions and to value them at market prices, leading their absence or falsity, to the application of a severe and sometimes disproportionate penalty regime.
Contrary to what is thought, this issue does not only affect large multinationals but also SMEs, which have not usually identified this area as a priority and are not as prepared as other larger companies.
At ANTEO we have a team specialized in transfer price and with a significant experience in this field. Therefore, we are by your side at all times and can assist you in a practical way, adapting to you and your needs.
Transfer pricing services
Our most significant services in transfer price and related party transactions are as follows:
- Advice on compliance with transfer pricing tax obligations (master files, country files, tax forms 232, etc.) to minimize the risk of penalties;
- Transfer pricing audits to diagnose risks and areas for improvement;
- Design and implementation of arm’s length transfer pricing policies that fit the company and its related party operations;
- Analysis and comparability studies (profitability studies, benchmarkings, etc.);
- Value chain analysis and transfer pricing restructuring (re-allocation of functions and risks);
- Remuneration of intangible assets;
- Assistance with inspection procedures (also in relation to professional partner remuneration); and
- Advanced Pricing Agreements (APAs) with the tax authorities to ensure legal certainty in the company’s transfer price policies.