BEPS Spain: New Rules for Transfer Pricing Documentation Released

On March 18, 2015, the PROYECTO DE REAL DECRETO XX/2015, POR EL QUE SE APRUEBA EL REGLAMENTO DEL IMPUESTO SOBRE SOCIEDADES was released by the Spain government.

This document in Spanish which covers the Master file, Local file and CbC reporting template for transfer pricing documentation purposes is available here.

Chapter 5 (Capitulo V, pp. 25-34 of the document) relates to the Master file, Local file and CbC reporting obligations.

Seccion 2 of Chapter 5 pertains to CbC reporting. Spain has indeed aligned the threshold for CbC reporting on the preliminary OECD implementation paper released in February 2015, that is 750 million euros.

Seccion 3 is aligned with the Master file and Local file requirements as per the OECD guidance released on September 16, 2014 available here.

The question that one could ask is which country will be next to implement unilateral measures before the release of the final OECD guidance on transfer pricing documentation?

Robert Robillard, Ph.D., CPA, CGA, MBA, M.Sc. Econ.
Senior Partner, DRTP Consulting Inc.
514-742-8086; robertrobillard “at” drtp.ca
www.drtp.ca

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