Spain Transfer Pricing Policy

Email: bcn4ww@evershinecpa.com
The Engaging Manager from Headquarter
Ms. Anna Wang, Speak German English, and Chinese.
skype: burlinna

TP-Q-10

Why kinds of scenario will be adopted TP policy? What is relevance between DTA and TP policy?

TP-A-10

When Spain Tax entity would like to pay out whatever Business profits, Royalty, Technical Services fees, Interests, Trading amount etc., it will adopt DTA tax rate. Its judge criteria, please see the Spain Treaty Page.

But if want to verify the above-mentioned amount if reasonable, will adopt Spain TP Policy.

TP-Q-20:          

What are the scenarios in Spain, that a Wholly Foreign-Owned Entity (WFOE) exempted from compliance of Transfer Pricing (TP) declaration and TP documentation?

TP-A-20:

Form 232

1. Transactions carried out between entities belonging to a group of companies that has elected to apply the special consolidated tax regime for Spanish CIT purposes (regardless of the enterprise size).
2. Transactions between economic interest groupings (AIEs) and unincorporated joint ventures (UTEs), with some exemptions.
3. Transactions carried out in the context of public offerings (OPAs) or tender offers (OPVs).
4. Generally, transactions with the same related party carried out each year that do not exceed 250,000 euros (regardless of the enterprise size).

Master File –

Companies with consolidated turnover of less than 45 million euros.

Country-by-country (CbC) Report –

MNE’s consolidated turnover less than 750 million euros in the fiscal year preceding the year.

TP-Q-30:          

What are the scenarios in Spain, that a Wholly Foreign-Owned Entity (WFOE) required to submit TP declaration to country’s tax bureau?
What is the name of the TP declaration form?

TP-A-30:

Form 232. Generally, transactions with the same related party carried out each year that do not exceed 250,000 euros (regardless of the enterprise size).

TP-Q-40:          

What are the scenarios in Spain, that a Wholly Foreign-Owned Entity (WFOE) required to submit TP declaration and TP documentation to country’s tax bureau?
What is the name of the TP declaration form and TP documentation form?

TP-A-40:

Local and Master File –

The preparation should help with penalty protection.

Country-by-country (CbC) Report –

MNEs in Spain with annual consolidated group revenue equal to or exceeding 750 million Euros in the prior fiscal year.

Spain TRANSFER PRICING for professionals

Overview

Transfer pricing rules apply to transactions between related entities.

Spanish transfer pricing rules follow the OECD Transfer Pricing Guidelines, including the arm’s-length principle.

Related companies

In general, shareholding participation is at least 25% to be related party.

Permissible Pricing method

*Comparable Uncontrolled price method (CUP)

*Resale price method (RPM)

*Cost-plus method (CPM)

*Profit split method (PSM)

*Transactional net margin method (TNMM)

Due dates and respective threshold:

Please be aware of below Warning:
The above contents are digested by Evershine R&D and Education Center in December 2022.
Regulations might be changed as time goes forward and different scenarios will adopt different options.
Before choosing options, please contact us or consult with your trusted professionals in this area.

Contact Us

Barcelona Evershine BPO Service Limited Corp.
Email: bcn4ww@evershinecpa.com
The Engaging Manager from Headquarter
Ms. Anna Wang, Speak German, English and Chinese.
skype: burlinna

or
For how to exchange data files between your Finance Accounting System and Evershine Cloud Accounting Information System, please send an email to HQ4fra@evershinecpa.com
Dale Chen, Principal Partner/CPA in Taiwan+China+UK will be accountable for your case.
LinkedIn address: Dale Chen

Additional Information

Evershine CPAs Firm Headquarters
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Partner Kerry Chen, USA Graduate School and a well-English speaker
Tel No.: +886-2-27170515 ext. 105
Mobile: +886-939357000
Email: kerrychen@evershinecpa.com
Skype: oklahomekerry

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(version: 2024/07)

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