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Connected Party Transacctions

Tare laws laying down rules implementing the system applicable to connected party transactions, regulating such matters as documentation and procedures and introducing a new form of a withholding and interim payment obligation.

This means that a tax obligor is faced with a number of new specific tax obligations, which are neither few nor negligible, merely by being involved in transactions concluded with persons or entities with which the obligor is howsoever connected.

The firm has broad-ranging expertise in regard to transfer pricing and the paperwork for the different conceivable transactions between connected parties.

The regulatory framework containing the rules governing all aspects to be borne in mind is as follows:

Royal Decree-Act 897/2010, 9th July, amending the Corporation Tax Regulations, approved by Royal Decree 1777/2004, 30th July, on documentation obligations for the connected party transactions.

Royal Decree-Act 6/2010, 9th April, on measures for boosting Economy Recovery and Employment.

Royal Decree 1793/2008, 3rd November, amending the Corporation Tax Regulations.

Tax Fraud Prevention Measures Act 36/2006, 29th November (LMPFF).

Royal Decree 1777/2004, 30th July, Corporation Tax Regulations (RIS).

Legislative Royal Decree 4/2004, 5th March, approving the Consolidation of the Corporation Tax Act (TRLIS).