The DEMPE Concept and Its Role in Domestic Transfer Pricing Practice – Report on Spain

Spain’s transfer pricing landscape for intangibles is defined less by domestic rules and more by an OECD-anchored DEMPE scrutiny. This theoretical approach creates practical gaps – such as valuation evidence and allocation over long development cycles – which, in turn, drive audit controversy. With a number of hot-button issues, contemporaneous documentation and proactive dispute resolution strategies (MAPs/APAs) become decisive. This article is part of a special issue of the International Transfer Pricing Journal on the DEMPE concept in domestic transfer pricing practice. The other articles include the General Report and contributions on Belgium, France, Germany, Ireland, Italy, Korea, Luxembourg, Netherlands and the United States.