Precios de transferencia

How an analysis of the value chain is able to benefit a company?

The value chain shows, separately, each action carried out by a company within the framework of its core activities. A value chain can include two types of activities according to their involvement in the development of the main company’s activity. These are primary and support activities. Primary activities are those…

The Transfer Pricing adjustment does not impact on the customs value of imported goods. Judgment of the European Court of Justice of December 20th, 2017

The European Court of Justice published in December 20, 2017 a sentence (case C-529/16) that decouples the prices agreed between related entities and the customs value declared. This relation was proposed by the World Trade Organization by 2015, through the publication of the Customs Valuation and Transfer Pricing Guide. This…

New Guidance on the implementation of Country by Country Reporting

The next 31st December,2017 is the deadline to submit the Country by Country reporting for the taxpayers that are bound to complete it and their fiscal year ended on 31st December, 2016. Country by Country reporting applies to multinational enterprises groups with an annual consolidated group revenue of EUR 750…

The profit split method in Transfer Pricing

The intra-group transactions must be valued according to the arm’s length principle, and that is very known. The problem lies on the selection of the appropriate transfer pricing method for each case. Obviously, the selection of the method depends on the type of transaction and the availability of the information…

Do you know the new form 232 to inform the Spanish Tax Authorities about the related-party transactions and transactions related to tax havens?

This disclosure statement was approved on 28th August, through the HFP/816/2017 ministerial order, to inform about the following situations: (a) related-party transactions; (b) related-party transactions, in case of application of the reduction of income from certain intangible assets (known as Patent Box); and (c) transactions and situations related to tax havens. For periods prior to…