Major amendments to transfer pricing legislation

Spanish corporate tax legislation has been amended to take into account the growing delivery of support services and licensing of intangibles by Spanish parent companies for and to their non-resident subsidiaries. The costs of these services need to be passed on to the foreign subsidiaries, in accordance with the rules set down in the OECD Guidelines. This article describes the main elements of the new Article 16 of the revised Corporate Income Tax Law and its future implementation by regulations, including changes to corporate income tax legislation, changes to non-resident income tax legislation, and changes to the VAT Law.