Cumplimiento tributario cooperativo y precios de transferencia

Abstract

Controlled transactions and transfer pricing tend to produce high levels of tax disputes, especially within large multinational groups. This conflict is negative both for the tax administrations and for the taxpayers.
It is necessary to design tools for cooperative compliance with tax obligations in transfer pricing. In this sense, the Avanced Pricing Agreements (APA) stimulate tax compliance, avoid conflict and provide legal certainty to taxpayers.

This paper analyzes the most important aspects of APAs, the procedure for their adoption in Spanish tax law, and highlights the importance of expanding their scope to all taxpayers, especially after the consequences caused by the Covid-19 pandemic.