Spanish transfer pricing legislation explicitly endorses the application of the OECD Guidelines and those of the European Union Joint Transfer Pricing Forum (EUJTPF) — country by country reporting, master file and country-specific concepts are required.
Taxpayers’ documentation, when requested to be disclosed, should include the identification of the companies involved in the related transactions, legal, organizational and operational structure of the group, nature and volume of the intra-group transactions carried out, functional analyses of such transactions, transfer pricing policy applied to set the prices of the transactions and transfer pricing methodologies and economic analyses used to test such prices.