El régimen de documentación de las operaciones vinculadas

Abstract

The Tax Fraud Amendment Act changed the Spanish fiscal regime on transfer pricing, introducing for the first time in this field a documentary obligation. Taxpayers are concerned due to the existing lack of experience in this area in our country, and taking into consideration the wide variety of obligations and the severe penalties [established by the above mentioned Act].
In this article we study the documentation regime, outlining the need to have an administrative action based on a proportionality principle and, de lege ferenda, a reduction of the level of obligations for the less material valuation cases.