Transfer Pricing 2026

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

tation quality and governance. For 2026, success will come from aligning the economics of how cash is pooled, how services are delivered, and how intangi - bles are developed and exploited, with a documen - tation suite that is contemporaneous, auditable, and consistent with OECD guidance and Spanish admin - istrative practice. In cash pooling, one should presume symmetric rates and group-level credit unless the facts support a dif - ferent conclusion with demonstrable risk control and financial capacity of the leader. In services, it is neces - sary to reserve the 5% simplified margin for truly low- value activities and evidence high-value capabilities with robust comparables or profit methods. In intan - gibles, one should keep DEMPE at the centre – and in benchmarking, it is important to navigate ranges with interquartile narrowing and a median anchor when warranted.

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