Under article 55 of the Spanish Insolvency Law, it is not allowed after the insolvency order to take individual enforcement action or initiate tax or administrative enforced collection proceedings against the debtor’s property; although until approval of the liquidation plan, administrative enforcement proceedings in which an attachment order has been issued are allowed to continue, together with enforcement actions for employee claims in which the insolvent company's assets have been attached, although certain restrictions apply. This means therefore that from when the liquidation phase commences enforcement proceedings can no longer be initiated to collect claims against the insolvent debtor, even if they are pre-insolvency claims.
In a particularly significant judgment on the subject of transfer pricing handed down on March 6, 2019, the National Appellate Court concluded on economic comparability analyses, and in particular, on selection of the point in the range of values from a sample to support the arm’s length nature of intragroup prices.