The Spanish Tax Reform for 2015 includes changes in regard to the country's transfer pricing rules. The main changes include:
- The definition of related parties for shareholders is changed from 5% shareholdings to 25% shareholdings
- The hierarchy of acceptable methods is abolished and all appropriate methods will be accepted as long as they comply with the principle of fair competition
- The revenue limit for simplified documentation is increased from €10 million to €45 million
- When no TP adjust…