Category: Transfer pricing
OECD opens public consultation process on its intra-group services transfer pricing guidelines
The proposed changes are a sign of the adoption of a more flexible approach to the analysis of these intra-group services, based mainly on reasonably foreseeable profits, which could also avoid automatism in tax regularizations. On 1 June, the OECD opened a public consultation process to update its transfer pricing guidelines for intra-group services (Chapter […]
Related-party transactions are consolidated as a preferential point of attention for the Public Treasury
In recent years, we have witnessed a notable increase in the investigation and verification of transfer pricing issues by the Spanish tax authorities. We review the most common controversies in this area, outlining potential recommendations. In recent years, the Spanish tax authorities have significantly increased their scrutiny of taxpayers on issues related to transfer pricing, […]