In transactions between unrelated companies, market forces often determine the terms of commercial and financial relationships, whereas between related companies such forces may not directly affect prices.
Entities with consolidated worldwide net turnover exceeding 750 million euros are obliged to file Form 231 from the day following the end of the tax period to which the information to be supplied refers until the following twelve months.
The information contained in the documentation to be made available to the taxpayer in the event of a request from the Tax Agency, varies depending on the net turnover of the companies.
Although the OECD considers transaction-based methods as the most straightforward methods to determine whether or not business relationships between related entities comply with the arm’s length principle, we will use one or the other depending on the type of transaction to be examined.
The increasing globalization and the presence of more and more companies in different countries forces us to know if our company is complying with the regulations established in the Spanish Corporate Tax Law (LIS) regarding Transfer Pricing in Spain.
Form 232 is an annual informative declaration of transactions carried out with related entities and/or related entities located in countries or territories classified as tax havens.