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Guide to friendly procedures

C.2 Who are the other parties involved in the transactions being examined and how do I identify them?

When identifying the parties involved, the taxpayer must take into account:

  1. If any of the parties to the transaction being examined belonged to a tax consolidation group during the years covered by the amicable procedure, the Group's information must be provided.

    The taxpayer must necessarily identify the parent company of the tax consolidation group (or the one who has the status of representative, if it is a horizontal Group) during the years covered by the amicable procedure.


    The Spanish company DEPENDENTY was part of the tax consolidation group in 2006 to 2012, of which the entity DOMINANTE was the parent.

    In 2016, the Corporation Tax for the years 2011 to 2014 for transactions with a related Belgian entity was settled with DEPENDENT.

    In 2018, DEPENDENT, which has not been part of the group since 2013, requests that an amicable procedure be initiated to eliminate double taxation that may have caused the Spanish liquidation.

    Although you are no longer part of the tax consolidation group, DEPENDENT must identify DOMINANT in the application form, because during the 2011 and 2012 financial years, which are the subject of the amicable procedure, he was a member of the tax consolidation group whose parent company was INDOMINANTE.

  2. The more information is provided, the less delays will occur in the procedure.

    Therefore, in the interests of the speed of the procedure, it is advisable for the taxpayer to be thorough in identification, especially with regard to foreign entities or persons.