ALS Transfer Pricing is the firm specializing in transfer pricing and valuations. We develop rigorous analyses that provide fiscal certainty and technical support for your company's decisions.
Services
At ALS Transfer Pricing, we advise, analyze, and document related-party transactions, in addition to valuing companies and assets. We provide technical rigor, strategic vision, and full regulatory compliance in an increasingly demanding international environment.
We advise national and multinational groups on compliance with the arm’s length principle. From initial diagnosis to documentation and technical defense, we provide a comprehensive approach that combines regulatory expertise with strategic business insight.
We conduct robust comparability studies using reliable sectoral data, market intelligence tools, and international databases. We help define appropriate profit margins, market prices, and internal policies aligned with tax regulations.
We design transfer pricing policies consistent with OECD Guidelines and local regulations. Our services include support in business reorganizations, intellectual property management, digital business models, and global value chain analysis.
We prepare Local File, Master File, and Country-by-Country Report (CbCR) in line with BEPS requirements and tax authority standards. Our reports ensure clarity, accuracy, and technical consistency to reduce risks during audits and inspections.
We provide technical support in tax audits, APAs, MAPs, and litigation. Our team combines expertise in economic-financial arguments with legal coordination to safeguard your organization’s interests.
We perform tax valuations and related-party transaction analyses, covering loans, guarantees, treasury services, and other financial instruments. Our reports apply recognized methodologies (DCF, multiples, substantial value) aligned with tax law and OECD standards.
Director TP & Valuations
Director TP
Analyst - Transfer Pricing
On the ALS Transfer Pricing blog, we share the latest news, analysis, and case studies on transfer pricing, business and asset valuation, international taxation, and regulation.
Explore how to optimize your tax strategy, stay up-to-date with regulatory changes, and access specialized content that will help you make informed decisions with legal certainty and strategic vision.
2025 is shaping up to be a pivotal year for the convergence of global transfer pricing rules. Recent OECD publications and stepped-up cross-border enforcement indicate a move toward standardisation, stronger documentation coherence, and integrated control of intragroup operations.
The Spanish Supreme Court’s Ruling STS 3721/2025 establishes a new precedent on remuneration within cash pooling systems, limiting the financial margin of the pool leader when no relevant functions or risks are assumed. ALS Transfer Pricing analyzes the impact of this decision and offers guidance for reviewing intragroup policies.
The G7 agreement on Pillar Two introduces greater flexibility and complexity in international taxation, directly impacting multinational transfer pricing strategies. ALS Transfer Pricing offers expert services to assess the impact of the new BEPS framework, redesign tax policies, ensure compliance, and reduce risk in an increasingly demanding global environment.
Sustainability is redefining transfer pricing policies. ALS Transfer Pricing integrates ESG factors into multinational tax strategy through green intangible valuation, efficient cost allocation, and AI-based solutions to ensure compliance, consistency, and corporate reputation.
FAQs
Find answers to the most common questions on transfer pricing, required documentation, and international tax compliance. Practical information and examples for your business.
Transfer pricing refers to the value set for goods, services, or financing transactions between related companies. These must follow the arm’s length principle to comply with tax regulations.
Because it ensures that intra-group transactions are carried out at market conditions, preventing penalties, tax adjustments, and double taxation from tax authorities.
The Local File is mandatory documentation detailing a specific entity’s related-party transactions, economic analysis, and applied policy. It is required under OECD BEPS and local tax regulations.
The Master File compiles global information of a multinational group: organizational structure, value chains, intangibles, financing, and transfer pricing policies. It must be consistent with each country’s Local File.
- Transactions per counterparty: there is no obligation to document if the total amount of transactions with the same related party is less than €250,000 in the fiscal year.
- Master File: it is exempt when the net turnover of the consolidated group is less than €45 million.
- Simplified content: if the consolidated group’s net turnover is less than €45 million, the regulations allow preparing documentation with simplified content, except for specific transactions (intangibles, real estate, businesses, unlisted securities, or with entities in non-cooperative jurisdictions), where full documentation is always required.
Note: To consult the limits and obligations in other countries, please review our OECD section.
The documentation must be available on the corporate tax filing date. The tax authorities may request it at any time and usually grant very short deadlines for submitting it. Therefore, it is advisable to prepare the documentation within the legal deadlines, avoiding doing so after the fact, as a report prepared after the request can be questioned and even penalized.
Whenever it carries out related-party transactions, domestically or internationally. The obligation to prepare documentation depends on local thresholds and OECD BEPS requirements.
Noncompliance can result in significant tax adjustments, increasing the tax base and generating additional taxation. Furthermore, failure to provide adequate documentation can lead to specific penalties, both financial and procedural, and increase the risk of conflicts with tax authorities, both in Spain and internationally.
More than just an advisor, at ALS Transfer Pricing we become your trusted partner, supporting you through every key decision.