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Practical Handbook for Companies 2021

Summary table

Documentation obligations for related-party transactions
Obliged to submit specific documentation (*)From the groupFrom the taxpayer
Net turnover ≥ 45 M €.
Net turnover < 45 M €.
No Yes (**)
Small company

(*) Transactions excluded from the specific documentation requirement

  • Between entities of the same tax group

  • Carried out between AIE and UTES of the same tax group, except for UTES or other similar forms of collaboration that benefit from the exemption of income obtained abroad through EP (art. 22 LIS).

  • Transactions carried out in connection with public offers for sale or takeover bids for securities

  • Transactions with the same person or related entity, provided that the consideration for all transactions is ≤ 250,000 €.

(**) Transactions excluded from taxpayer-specific documentation with INCN < 45 M €.

  • Transactions with individuals who are taxed under the objective assessment method and whose shareholding, individually or jointly with their family members, is ≥ 25% of the capital or equity.

  • Transfer of securities or shares in the own funds of entities not admitted to trading or admitted in non-cooperative jurisdictions

  • Transfer of business, real estate and intangible assets transactions