Rocio Herrera Molina

Rocio has twelve years of experience in international taxation, specialising in transfer pricing since 2016. She joined BMC in 2020, where she manages transfer pricing documentation and benchmarking studies for multinational groups with a presence in Spain.

Her work covers everything from preparing the Master File and Local Files required under Spanish regulations to filing Advance Pricing Agreement (APA) requests with the Spanish Tax Agency and coordinating mutual agreement procedures (MAP) with foreign tax authorities. Before joining BMC, she worked on the transfer pricing team at a leading international firm, where she participated in projects for sectors including pharmaceuticals, technology, and organised retail.

APAs are one of the areas where Rocio adds the most value: the process of applying for and negotiating with the tax authority is lengthy and technically demanding, and groups that approach it without adequate preparation frequently achieve results below what they could have obtained. Her experience in APA negotiations — both unilateral and bilateral — allows her to design the submission strategy with a precise understanding of which arguments prove persuasive to the administration.

Country-by-country reporting (CbCR) and the implementation of BEPS recommendations — particularly Pillars 1 and 2 — now make up a growing part of her work, as the groups she advises reach the revenue thresholds that trigger those obligations. She has an in-depth knowledge of the OECD Transfer Pricing Guidelines and applies a rigorous approach both in the economic analysis of controlled transactions and in defending adopted positions in the event of a tax audit.

She holds a Master in Tax Advisory from ESADE and a degree in Economics from the Universidad de Málaga. She speaks Spanish and English at a professional level. Her knowledge of the OECD guidelines and BEPS regulations allows her to identify risk points in each group’s transfer pricing policy and propose documentarily sound solutions that withstand administrative scrutiny.