Transfer Pricing 2026

SPAIN Trends and Developments

Trends and Developments Contributed by: Carolina del Campo, Joan Hortalà, Jaime Collado and Pablo Álvarez Cuatrecasas

Cuatrecasas is an international law firm focused on business law and recognised for combining special - ised local knowledge with shared global resources to provide close, technical and client-tailored advice. The firm has 27 offices in 13 countries, with a par - ticularly strong presence in Spain, Portugal and Latin America, as well as teams in other international loca - tions such as Brussels, London, New York, Beijing and Shanghai. The firm brings together more than 1,700 professionals, works across 28 practice areas,

and provides support in the main areas of business law through a multidisciplinary approach and a con - sistent methodology. Cuatrecasas’ value proposition is also grounded in innovation, technology and an industry-focused perspective that enables support of companies in local, cross-border and highly complex matters. As a result, Cuatrecasas is positioned as an Iberian and international benchmark for companies seeking rigorous, efficient legal solutions aligned with their strategic business objectives.

Authors

Carolina del Campo is a partner in the transfer pricing practice of Cuatreca - sas. She has participated in many M&A transactions involving Spanish compa - nies investing abroad, advised on international tax matters, transfer

Jaime Collado is a senior associate in the transfer pricing practice of Cuat - recasas. He is an expert in designing policies for transfer pricing and transaction valuation, as well as in handling business restructurings and

pricing and the interpretation of double tax treaties, and negotiated mutual and advance pricing agree - ments. Carolina is a member of the Spanish High Body of National Tax Inspectors (on leave of absence) and a co-ordinator and deputy director at the Sub-Directo - rate General for Non-Resident Taxation (1997–2013). She was head of the International Relations Coordina - tion Unit and team co-ordinator in the National Office for International Taxation.

negotiating advance pricing arrangements with the tax authorities. Jaime also advises clients on the mandatory documents for related-party transac - tions, and on comparability analysis, and represents them before the tax inspectorate and in court. He assists clients in mutual agreement procedures and arbitration procedures to avoid double taxation.

Pablo Álvarez is an associate in Cuatrecasas’ transfer pricing team. He specialises in structuring transfer pricing frameworks and valuing intra-group transactions, as well as steering business reorganisations and

Joan Hortalà is a partner in the transfer pricing practice of Cuatreca - sas. He advises business groups with a strong international profile, enabling them to be taxed in line with their value chain. From 1992 to 2002, Joan

negotiating advance pricing agreements with the tax authorities. He counsels clients on the documenta - tion required for related-party dealings, and on comparability studies, and represents them in audits and litigation. He also supports clients in mutual agreement procedures and arbitration to eliminate double taxation.

was a member of the Spanish High Body of State Finance Inspectors and held several other positions, including national expert (European Commission), co-ordinator of double-taxation treaties (Directorate- General for Taxation), delegate of the Ministry of the Economy and Finance in the transfer pricing working group of the OECD, chief inspector of the Barcelona tax authorities and member of the company tax division of the Catalonian tax appeal board.

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