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TP focused analysis of new ground-breaking legislation to prevent tax fraud

Spain

On October 31, 2008, the Spanish Council of Ministers approved three Royal Decrees implementing the Law on Measures to Prevent Tax Fraud, amending the Corporate Income Tax Regulations, and approving the Regulations on Direct Taxation-Related Mutual Agreement Procedures.

According to the Preamble of the Law on Measures to Prevent Tax Fraud, the approval of the measures is aimed at improving the mechanisms for combating fraud, and at increasing legal certainty in taxpayers' dealings with the tax authorities as a way to encourage voluntary compliance and prevent fraud.

The most important questions addressed by the Royal Decrees in the area of transfer pricing are detailed in the attached newsletter alongside new documentation obligations in related-party transactions and an analysis of how cost contribution arrangements and APA arrangements have been affected.

 

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