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Practical Handbook for Companies 2021

Specific documentation relating to the group's related-party transactions

Related persons or entities must keep at the disposal of the tax authorities the documentation relating to the group to which they belong, including the permanent establishments forming part of the group.

In relation to this specific documentation obligation, a distinction must be made between:

  1. Groups in which the net turnover, defined in the terms established in article 101 of the LIS for small companies, is equal to or greater than 45 million euros.

    As foreseen in Article 15.1 of RIS, the group-specific documentation should comprise:

    1. Information concerning the structure and organisation of the group.
    2. Information on the group's activities.
    3. Information relating to the group's intangible assets.
    4. Information relating to financial activity.
    5. Financial and fiscal situation of the group.
  2. Groups in which the net turnover, defined in the terms established in Article 101 of the LIS, is less than 45 million euros, as established in Article 15.2 of the RIS.

    According to the provisions of this Article, these taxpayers do not need to have specific group documentation.