MadridBarcelonainfo@velardevidal.com
Legal & Tax firm
Spain · since 2023
V&V Velarde & VidalLegal & Tax
HomePractice areasTax & transfer pricing
Practice 04

Tax & transfer pricing

Facing the Spanish tax authority, preparation decides outcomes: solid documentation, a controlled calendar and a technically defensible position from the very first request.

We advise companies and groups on AEAT audits, appeals, the tax side of transactions and transfer pricing — coordinating the international dimension when the group operates across borders.

§ I

When clients call us

An AEAT audit has started

Opening notice, information requests and assessments: defence from day one.

An assessment or penalty arrived

Administrative appeals, economic-administrative claims and court review.

A deal with tax consequences

Acquisitions, reorganisations and intragroup financing: structure before signing.

Related-party transactions

Transfer-pricing policy and documentation that survives an audit.

Executives relocating

Coordination with the impatriate regime and the personal tax of shareholders.

§ II

How we work

01

Diagnosis

A tax-risk map: open years, contingencies and realistic exposure.

02

Technical position

A defence memorandum built on statute, doctrine and case law.

03

Procedure

Deadlines, information requests and hearings managed end to end.

04

Resolution

Assessment, appeal or settlement — decided on numbers, not instinct.

§ III

Track record

Anonymised for confidentiality; results illustrative.

Audit closed, no penalty

Corporate-tax and VAT audit of a retail chain closed with minimal adjustment and no penalty file.

Anonymised · illustrative
Assessment annulled

Transfer-pricing assessment annulled in the economic-administrative phase.

Anonymised · illustrative
Neutral reorganisation

Family-group restructuring executed under the tax-neutrality regime without contingencies.

Anonymised · illustrative
TP file ready in time

Master file and local file for a four-country group completed before the information request.

Anonymised · illustrative
FAQ

Frequently asked questions

What should we do when the AEAT opens an audit?
Spanish tax audits are governed by the General Tax Law (Law 58/2003): deadlines start running from the opening notice and everything you submit stays on the file. The consequence: do not answer the first information request without a strategy — what to provide, how to explain it, which years are genuinely open — because early positions condition the final assessment.
Can we appeal a Spanish tax assessment without paying first?
Yes. The General Tax Law lets you appeal and request suspension of the debt, normally against security such as a bank guarantee. The consequence: a debatable assessment need not be paid immediately, but suspension must be requested properly and in time; otherwise the debt enters enforced collection with surcharges.
What transfer-pricing documentation does Spain require?
Related-party transactions must be priced at arm's length and documented according to group size (group and taxpayer files). The consequence of not having them: valuation adjustments, specific penalties and a weak negotiating position in an audit. Preparing the benchmarking before the request costs a fraction of arguing it afterwards.

Tell us about your matter.
A partner replies.

No endless intake forms, no autoresponders. A partner reads your message and replies within two working hours.

  • A first orientation call at no commitment
  • Confidentiality from the very first email
  • Advice in English or Spanish
Tell us about your matter
Your data is processed under the GDPR and Spanish data-protection law and goes only to info@velardevidal.com. We never share it with third parties.