Spain vs. ZERAIM IBÉRICA, SA, Oct. 2016, Spanish Supreme Court, Case no 4675-2016

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In this case ZERAIM IBÉRICA SA argues that the OECD Transfer Pricing Guidelines has not been applied propperly, as secret comparables have been used in determining the arm’s length price of controlled transactions between the Spanish company and its Dutch parent company.

The court concludes that the “..Guidelines are considered to be merely recommendations to States, which are given an interpretative value.”

The appeal filed by the company is dismissed by the court.

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Spain vs Zeraim 191016 Spanish Supreme Court 4675-2016

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