Article 13.1 of the Corporate Income Tax Regulations (Reglamento del Impuesto sobre Sociedades, RIS), approved by Royal Decree 634/2015, regulates information and documentation on related entities and transactions. This article establishes that entities resident in Spain that qualify as the parent of a group, as defined in Article 18.2 of the Corporate Income Tax Law (LIS), and are not dependent on another entity, must provide the country-by-country reporting referred to in Article 14 of the RIS.

Entities resident in Spain that are subsidiaries of a non-resident entity, as well as permanent establishments in Spain of non-resident entities within the group, are also required to provide this information if any of the following conditions are met:

• There is no similar obligation in the country of tax residence of the non-resident entity.
• There is no international agreement for the automatic exchange of information between competent authorities.
• There has been systematic non-compliance with the automatic exchange agreement, as communicated by the Spanish tax authorities.

This article aims to ensure fiscal transparency and compliance with international tax obligations through the exchange of tax information between countries.