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Transfer Pricing in Spain
The Law 36/2006 on Measures for Preventing Tax Fraud

In order to prevent tax arbitrage, almost all OECD Member countries have agreed on implementing the arm’s length principle as the international standard to be used for determining transfer prices for tax purposes. The recently approved Law 36/2006 on Measures for Preventing Tax Fraud includes an amendment to the article 16 CITL, which contains the basic Spanish rules concerning transfer pricing, in line with the international trend. In this working paper it will be outlined the basic international transfer pricing scenario as well as the new Spanish transfer pricing legislation.

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Antonio Fernández Crende, Alberto Álvarez Wilmanski, «Transfer Pricing in Spain. The Law 36/2006 on Measures for Preventing Tax Fraud», InDret 2.07