Technology and transfer prices

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Technology has emerged in recent years as a fundamental component of the increase in the businesses of multinational groups, being also essential for obtaining information by the tax administrations, as well as for the systematization and analysis of the same, the execution of specific inspection actions and the promotion of national and international collaboration in a world in constant change and evolution. The strategic objectives of the spanish tax agency are focused on strengthening assistance and preventing tax fraud, control actions have been intensified, with the ultimate goal of achieving voluntary compliance with tax obligations by taxpayers. Taking into account the large amount of information that they already have, one of the fundamental elements of the strategy of the spanish tax administration will be the use of the new automated risk analysis system, based on the use of technology to achieve the review and study of the set of information available on related party transactions, which it already has.

The foregoing, together with the greater knowledge Italy Telegram Number Data  that the tax administration has of multinational groups (both of their structure, operation and of the sectors in which they operate) will result in a more precise risk analysis, through the development of indicators. , indices and models, and the identification of patterns of behavior of potential significant fiscal risko. Therefore, at this time, beyond the concern in the formal aspects of transfer pricing (preparation of the corresponding documentation, in accordance with the requirements established by the regulations of each jurisdiction), lhe different tax administrations are focusing, thanks to the analysis they carry out through the use of technology, in which multinational groups align, effectively, its tax model with its business operations and value generation, considering for this not only the strategic and decision-making functions but also the legal and economic ownership of intangible assets as the most relevant elements.



In the field of informative returns, the spanish tax administration is also giving relevance to the use of technology to launch campaigns to verify proper compliance with reporting obligations on related-party transactions (form 232- informative declaration of related operations and of operations and situations related to countries or territories classified as tax havens-). Likewise, and with regard to model 231 (country-by-country information declaration –cbc/dac4-), the great challenge of the tax administrations is the detailed analysis of the data provided, and the drawing of conclusions that allow him to direct his subsequent actions. Other issues that deserve special attention would be, in the first place, the actions of the tax administrations aimed at analyzing the compliance with the arm's length principle of the corporate restructurings carried out to adapt multinational groups to the new business reality, in accordance with the provisions of chapter ix of the oecd guidelines. administration and its growing ability to analyze and conclude on it thanks to the use of the technology it has.