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Spanish National Court Holds Tax Authority May Not Default to Median of the Arm's Length Range Without Reasoning

|Approved Changes|Spain
Spain

A decision of the Spanish National Court was published on 29 July 2023 on the tax authority defaulting to the median of the arm's length range when making transfer pricing adjustments. The case involved a Spanish manufacturer of non-electric stoves, heaters, and domestic heating appliances, Ferroli Spain, which is wholly owned through a Luxembourg holding company by an Italian company, Ferroli…

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