Holtrop S.L.P. blog
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In case 8/2009 the Spanish Supreme Court has remitted a constitutional appeal in a case about Royal Decree 1793/2008, on transfer pricing. The issue at stake is the obligation of the affected companies to have relevant documentation on transfer pricing, whereas the content of such documentation has not yet been established with the required precision. The appeal aims at the lack of a legal base for administrative fines in this respect. Furthermore, proportionality issues are invoked, since the Law allows for further regulation to increase the applicability of penalty to assure compliance with the obligation at stake. You can download the appeal here:

Cuestión de inconstitucionalidad Real Decreto 1793/2008