The Spanish tax authorities will be paying closer attention to related companies who invoice one another. This effort will attempt to prevent the shifting of capital gains between partner companies. In cases where this is found to be occurring, the authorities will be checking to see if companies are conforming to the rules regarding contractually binding, standard market pricing.

Furthermore, we have observed that the authorities are adopting a stricter stance when it comes to regulating the role intercompany accounts play between the enterprise and the shareholders. In cases where companies are not in compliance with the strict rules governing intercompany accounts, these will be construed as loans by the authorities. As such, companies will be required to adhere to the rules that govern loans (contracts, interest, etc.).

Efforts to gain control over these issues will be given top priority by the Spanish tax authorities in 2010.