Transfer pricing

The Spanish legislation for Transfer Pricing has undergone major changes.  The new rules include new obligations for the taxpayer:


  • Information related to transactions between related parties must be included in the Corporate Tax declaration.
  • The obligation to prepare and keep the documentation about related party transactions.
  • The valuation of every transaction must be done according to the arm’s length principle (market value).
  • The burden of the proof is on the taxpayer.
  • A new penalty regime with tax penalties for failing to deliver the required documentation properly.


UHY Fay & Co has a team of experts specialised in Transfer Pricing that will help you organize a global strategy that will maximise the efficiency on transactions and minimise tax risks. We will also take care of all the paperwork related to it such as the creation of the mandatory master file.

Click here to see the new transfer pricing reporting From 232