Transfer pricing for VAT in Spain

Directive 2006/69/EC opened up the possibility for the tax authorities to adjust the valuation of certain transactions of goods or services in specific circumstances in the case the value declared differs from the "open-market value". This article provides details of the new Spanish transfer pricing arrangements that were adopted on the basis of the provisions of this Directive and examines them against the background of the EU legislation in order to provide an insight into their scope and content, both from a subjective and an objective point of view.