Spain Adopts New Transfer Pricing Documentation Requirements including CbC Reporting

Spain has published Royal Decree 634/2015, which includes new transfer pricing documentation requirements including the implementation of the country-by-country (CbC) reporting requirement developed as part of Action 13 of the OECD BEPS Project. The new requirements apply for fiscal years beginning on or after 1 January 2016.

CbC Report Filing Obligation

The CbC reporting requirement applies for Spanish resident entities that are the head of a corporate group and are not held under any othe…