Tag: ocde

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.

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.

The Colombian Supreme Administrative Court supports the inclusion of loss-making comparables if they maintain similar functional conditions, rejecting their automatic exclusion. This decision strengthens alignment with OECD guidelines and requires tax authorities to conduct more rigorous technical and economic analyses.

LATAM tax authorities are tightening transfer pricing controls with new obligations, audits, and alignment with OECD standards. At ALS Transfer Pricing, we offer expert advisory services to help companies anticipate risks, ensure regulatory compliance, and adapt their tax strategies across the region.