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- Title
Las operaciones vinculadas en el Impuesto sobre Sociedades.
- Authors
Fernández, Javier Martín; Seoane, Juan Manuel Berdud
- Abstract
This article examines Article 16 of the Income Tax, comparing the current regulation. This article was the subject of a thorough reform at the hands of the Tax Fraud Prevention Act (LPFF), which was justified by the desire to bring Spanish legislation to the OECD Guidelines and the European Pricing Forum transfer. In LPFF states that the aim of regulation of related party transactions should be to address the depletion of Spanish bases using transfer pricing by multinational groups. They are rules whose scope should be the nature of transactions with persons or entities not resident. The new art. TRLIS 16 is drafted so that its implementation is widespread, both international operations as domestic ones.
- Subjects
TAX laws; INCOME tax; TAX evasion; TRANSFER pricing taxation; TAX auditing; INTERNAL revenue
- Publication
Partida Doble, 2010, Vol 21, Issue 223, p48
- ISSN
1133-7869
- Publication type
Article