Tag: precios-de-transferencia

Knowing in advance what documentation the Inspector will look for allows companies to prepare early and reduce the impact of a tax audit.

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

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.