0
Royalties and intangibles: how to defend the market price before the AEAT
The transfer of intangibles between group companies receives close scrutiny from the Inspectorate. The DEMPE analysis and valuation method choice are decisive.

0
The transfer of intangibles between group companies receives close scrutiny from the Inspectorate. The DEMPE analysis and valuation method choice are decisive.

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.
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.
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.
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.