Spanish Supreme Court raises doubts on the Constitutionality of the Transfer Pricing Law

Basically the Supreme Court questions the breach of the principle of legality laid down in article 25.1 CE related to criminal and administrative penalties. This constitutional provision includes the principles of lex certa and typicity in the sense that it must be a Law the instrument to be used to establish which act or omission constitutes an offense and what its punishment is, and that the Law must be clear and ascertainable in order to determine the offense and the penalty…