Transfer Pricing

We provide advisory services for the best design and business structure to implement the tax obligations of Transfer Pricing, as well as optimizing the risk management that derives from these legal obligations by minimizing such risks.

Our professionals also provide advice in the planning and structure of the business activity, preventing and anticipating tax risks that could be generated in application of the tax guidelines, as well as optimizing taxation both nationally and internationally.

We offer professional services in transfer pricing for each step of the growth of your business. Our services include:

  • Advice, supervision and preparation of transfer pricing documentation (Masterfile and Localfile) in compliance with Spanish and foreign tax regulations.
  • Assistance in regards to tax inspections.
  • Advice and assistance in the preparation of Prior Valuation Agreements, and Mutual Agreement Procedures or Arbitration Agreements to avoid double taxation.
  • Transfer pricing risk analysis: due diligence.
  • Business restructuring and reordering of the value chain to optimize business and tax benefits.
  • Intragroup services defense file.
  • Analysis of a permanent establishment’s risk situation.
  • Preparation of distribution, manufacturing, services and fees contracts, among others, that accredit and justify related operations.
  • Analysis and support of situations of continuous losses (10 years).
  • Completion of models 232 and 231.
  • Tax planning and optimization.
  • Analysis of operations between the Business owner and Company.


The Transfer Pricing Department RSM Spain analyzes and studies the specific situation of each client in order to provide a customized service accompanying them from the risk analysis and identification stage, to the elaboration phase of the required regulatory documentation in a coordinated manner with those responsible of the company.