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Practical Manual of Companies 2022.

Summary table

Obligated to document related operations
Obliged to present specific documentation (*)Of the groupFrom the taxpayer
Net amount of turnover ≥ €45 M 
Yes Yes
Net turnover < 45 M €
No Yeah (**)
Small company
No Yes

(*) Operations excluded from the obligation of specific documentation

  • Made between entities of the same tax group

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

  • Operations carried out in the context of public offers for sale or public offers for the acquisition of securities

  • Operations carried out with the same person or related entity as long as the consideration amount for the set of operations is ≤ €250,000

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

  • Operations with natural persons who pay taxes in an objective estimate that the participation individually or jointly with their family members is ≥ 25% of the capital or own funds

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

  • Transfer of businesses, real estate and operations on intangible assets