Tax Commentary 9-2014


New Transfer Pricing provisions on the Spanish Corporate Income Tax

Please find below a summary of the main Spanish corporate income tax amendments that have taken place in relation to controlled transactions following the approval of the corporate income tax reform in Law 27/2014 of November 27, 2014.

1. Rules on determining related parties

2. Documentation obligations

3. Transfer pricing methods

4. Related-party transaction categories

5. Permanent establishments

6. Advance pricing arrangements with the tax authorities

7. Secondary adjustment

8. Procedure for reviewing the arm’s length value

9. Infringement and penalty regime

10. Transactions performed with or by entities resident in tax havens

11. Reduction of the income obtained on certain intangible assets (“Patent Box”)


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