Tranfer pricing: The TEAC Extends the Scope of Related-Party Status to Indirect Shareholders
Cambio relevante en materia de precios de transferencia
The Central Economic-Administrative Court (TEAC) has introduced a significant change in the field of transfer pricing, extending the concept of related parties to include individual shareholders with indirect shareholdings of 25% or more. This new criterion represents a departure from the previous administrative interpretation and has a direct impact on transfer pricing documentation, Form 232, and the tax treatment of transactions across different taxes.
In this tax alert, we analyse the scope of the TEAC resolution, its practical consequences for companies and family-owned groups, as well as the key recommendations for reviewing transactions, tax filings, and tax risks under this new framework within Spanish transfer pricing regulations.
You can download the full tax alert in the module on the right.
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