How to produce a defensible transfer pricing benchmarking study
A poorly built benchmarking study can be worse than having none. The AEAT can use it against the taxpayer if the selection criteria are inconsistent.
Specialists in transfer pricing and related-party transactions
We help national and international groups design, document and defend their transfer pricing policies before the tax authorities, with economic analyses, benchmarks and solid valuations.
+20
Años de experiencia
+400
Clientes
+20
Profesionales
2
Oficinas
How we can help you
Do you have undocumented related-party transactions?
We review intra-group transactions, identify tax risks and prepare the documentation needed to defend the applied policy before the tax authorities.
Have you received a request from the tax authorities?
We prepare technical-economic arguments, review comparables and strengthen the defence of the transfer pricing policy applied by the group.
Do you need a defensible benchmarking study?
We select comparables, justify search criteria and document the arm's length range to reduce the risk of adjustments during an audit.
Services
What do we do at ALS Transfer Pricing?
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.
Transfer Pricing Consulting
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.
Economic Analysis and Benchmarking
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.
International Compliance and Group Reorganization
We design transfer pricing policies consistent with OECD Guidelines and local regulations. We support business reorganizations, intellectual property management, adaptation to digital business models, and global value chain analysis.
Documentation and Regulatory Compliance
We prepare Local File, Master File, and Country-by-Country Report (CbCR) in a clear, comprehensive manner aligned with BEPS requirements and tax authority standards. We ensure technical accuracy and consistency to minimise risks in audits and inspections.
Audit Defence and Litigation
We provide technical support in tax audits, contributing robust economic-financial analyses and legal coordination to defend your organisation’s interests. We also have extensive experience in international mutual agreement procedures (MAPs) and Advance Pricing Agreements (APAs) — key tools to prevent or resolve transfer pricing disputes in a global environment.
Valuations and Financial Transactions
We perform tax and financial valuations of all types of assets: businesses, business units, loss of profit, emerging damages, and intangibles (brands, software, goodwill, image rights, know-how, etc.). We apply recognised methodologies and guarantee technical soundness in line with tax law and OECD standards.
Our Team
Marc Cairols
Partner of Transfer Pricing and Valuations
Mónica López
Director of Transfer Pricing
Marta Victoria
Senior Analyst of 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.
How to justify intragroup services between related companies
For an intragroup service to be deductible, it is not enough to have it recorded in the accounts. The AEAT requires proof that the service was actually performed.
10 errors in transfer pricing documentation that the AEAT can review
A deficient Local File not only exposes the taxpayer to formal penalties. These are the most common errors detected by the AEAT in its reviews.
Transfer pricing guide in Spain 2026
Complete summary of transfer pricing obligations in Spain: who must document, what to include, when to file Form 232 and how to prepare for an inspection.
FAQs
Frequently Asked Questions about Transfer Pricing
Find answers to the most common questions on transfer pricing, required documentation, and international tax compliance. Practical information and examples for your business.
What is transfer pricing?
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.
Why is transfer pricing important?
Because it ensures that intra-group transactions are carried out at market conditions, preventing penalties, tax adjustments, and double taxation from tax authorities.
What is a Local File in transfer pricing?
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.
What is a Master File in transfer pricing?
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.
What are the documentation thresholds in Spain?
Under the Spanish common regime, there is no obligation to document transactions with the same related party below €250,000 per year. Above that amount, groups with consolidated turnover below €45 million may prepare simplified documentation; those above the threshold must document in full. The Master File is only required for groups exceeding €45 million in consolidated turnover.
Note: To check thresholds in other countries, see our OECD section.
What are the deadlines for submitting transfer pricing documentation?
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.
When can my company be required to document its transfer pricing policy?
Whenever it carries out related-party transactions, domestically or internationally. The obligation to prepare documentation depends on local thresholds and OECD BEPS requirements.
What consequences can result from not complying with transfer pricing regulations?
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.
ALS Transfer Pricing
More than just an advisor, at ALS Transfer Pricing we become your trusted partner, supporting you through every key decision.