Transfer pricing Spain: The tax authorities are tightening the reins

With a strong focus from the Spanish tax authorities (AEAT) and clear regulatory evolution, multinational groups operating in Spain must now ensure that their transfer pricing documentation and methodologies are not only compliant, but also technically sound and defensible.

Transfer pricing in the focus of auditors

The 2025 Spanish Tax Control Plan prioritises transfer pricing (TP) as a central area of inspection. It places particular emphasis on intra-group services, financial transactions, business restructurings, intangible asset transfers, and entities with recurring losses. The authorities are increasingly verifying whether “low-risk” entities – typically distributors or contract manufacturers – actually assume the limited risks they claim, with proper functional and financial segmentation.

Tax authorities with new methodology

At the same time, Spain continues to refine its practical approach. One important trend is the use of interquartile ranges for setting and assessing arm’s length prices. Following OECD guidelines and national case law, the AEAT generally allows taxpayers to justify their pricing within a reliable interquartile range. However, if results fall outside the range, adjustments are commonly made to the median – unless, based on facts and circumstances, the taxpayer can prove why another point within the range is more accurate.

We advise clients on the design of transfer pricing strategies, audits, APA negotiations, and litigation.

Mariajosé Díez Escalona, Transfer Pricing Manager, ECOVIS Audit Madrid, Madrid, Spain

Documents required by the tax administration

All of this underlines the growing technical sophistication expected by the Spanish tax administration. It is no longer enough to submit formal documentation: authorities are requiring substantive analysis, robust comparisons and economic logic. Spain is also actively using mutual agreement procedures (MAP) and advance pricing agreements (APA) to avoid double taxation and reinforce cooperative compliance.

Multinational groups operating in Spain should reassess their TP documentation, validate their economic models, and review their internal comparisons – especially where low-risk entities are involved, recommend the Ecovis experts. Pre-emptive dialogue with authorities via APAs may also be a strategic tool to reduce audit risk.

For further information please contact:

Mariajosé Díez Escalona, Transfer Pricing Manager, ECOVIS Audit Madrid, Madrid, Spain
Email: mariajose.diez@ecovis.es