SPAIN Law and Practice Contributed by: Cristina Alba and José María Rodríguez Hernández, act legal
Co-operative Compliance and Enhanced Engagement
Additional Advance Agreements Spain also offers advance agreements beyond tradi - tional transfer pricing APAs. Taxpayers can enter into agreements regarding the valuation of R&D expenses and the qualification or valuation of income derived from intangible assets, including patent box regimes.
Spain has also established a voluntary co-operative compliance system in addition to formal rulings. Tax authorities have set up structured forums for large businesses, small businesses, and other taxpayer organisations through the “Cooperative Relationship” model and the Code of Good Tax Practices. These forums are based on the principles of transparency and mutual trust and foster a mutually co-operative relationship between the Tax Agency and taxpayers. This framework reduces the legal uncertainty to which companies could be exposed and the litigation that arises between them and the Tax Agency.
442 CHAMBERS.COM
Powered by FlippingBook