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Practical Manual for Companies 2022.

Summary table

Required to provide documentation in related-party transactions
Required to submit specific documentation (*)Of the groupFrom the taxpayer
Net turnover ≥ €45M 
Yes Yes
Net turnover < €45M
No Yeah (**)
Small company
No Yes

(*) Operations excluded from specific documentation requirements

  • Carried out 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 are eligible for the exemption of income obtained abroad through EP (art. 22 LIS )

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

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

(**) Operations excluded from specific documentation of the taxpayer with INCN < 45 M €

  • Transactions with individuals who pay taxes on an objective basis, in which the individual or joint participation with their family members is ≥ 25% of the capital or equity

  • 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