Transfer Pricing

The increasing activity of companies in a globalised environment has substantially increased the number, relevance and typology of intra-group transactions. Taxpayers are also faced with a constantly evolving legal framework, tax authorities with increased resources, and greater collaboration between them as a result of the new international framework established by the OECD-led BEPS Project.

BDO offers its clients integrated, tailor-made solutions ranging from risk identification to implementing solutions and/or the planning of transfer pricing policy.

We work in collaboration with our BDO Global Transfer Pricing Services team, and supported by the resources of this extensive and highly skilled international transfer pricing network, we are able to tailor our transfer pricing services in a way that adds value to our clients' businesses.

Our services

1.- Surveillance and Design

  • Analysing the consistency of a Group’s transfer pricing policy with their business and financial results.
  • Flow planning and value optimization.
  • Providing support of internal control and assistance with regards to the design of ad-hoc operations.

2.- Defence and documentation

  • Advising on compliance with transfer pricing documentation obligations (Master files, Local file, Country-by-Country reporting, local filing requirements, benchmarking support).
  • Preparing transfer pricing documentation and benchmarking support for routine and non-routine activities, including financial transactions and intellectual property.
  • Advising on the minimization of the risk of formal sanctions.
  • Diagnosing risk from transfer pricing policies applied, identifying action plans, and supporting with enquires or inspections.
  • Advising on prior valuation agreements (APAs) on transfer pricing policies, advising on, and guiding, the APA process with the Spanish Tax Authorities.

3.- Sanctions and Adjustments

  • Advising on the minimization of the formal sanctions / tax procedures from the Spanish Tax Authorities.
  • Defending the characterization of operations and income.
  • Assisting with the prevention/minimization of tax adjustments that may affect future years and impact the Group's financial plan.

4.- Risk Diagnosis and Inspection Support

  • Defending secondary tax adjustments, i.e., Corporation Tax and Personal Income Tax.
  • Diagnosing adjustment risks to individuals who have professional income.
  • Diagnosing of the BEPS impact on the business structure.

5.- Value Chain and Benefit Allocation

  • Reorganizing functions and risks.
  • Advising on the remuneration of intangibles.
  • Advisory on operations and international expansion.