SPAIN Law and Practice Contributed by: Carolina del Campo, Joan Hortalà, Jaime Collado and Pablo Álvarez, Cuatrecasas
16. Transparency and Confidentiality 16.1 Publication of Information on APAs or Transfer Pricing Audit Outcomes The Spanish Tax Administration only publishes gen - eral information about the number of APAs negotiated or initiated in a specific year for statistical purposes. No other information is available. General information is made public in respect of the collection of each type of tax, but no details are disclosed.
16.2 Use of “Secret Comparables” The use of secret comparables is not permitted in Spain; the data used by the tax authorities needs to be disclosed to the taxpayer in order to make an adjustment.
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