In accordance with Article 30 of the Transfer Pricing Regulation Act, taxpayers who engage in transactions with related parties or with individuals or legal entities covered by special regimes that provide tax benefits must file the Annual Informative Affidavit on Transfer Pricing (DJMPT). The filing deadline is April 30 for taxpayers whose tax periods end on December 31.
* For taxpayers with special tax periods, the deadline is within 3 months following the end of the tax period.
FORMAL OBLIGATIONS;
Taxpayers required to file the Informative Transfer Pricing Return are those that meet at least one of the following conditions:
- Taxpayers classified as medium or large taxpayers who engage in commercial or financial transactions with related parties
- Taxpayers who engage in commercial or financial transactions with entities covered by special regimes that enjoy tax benefits
- Taxpayers who conduct commercial or financial transactions with companies domiciled in tax havens.
- Small taxpayers who conduct transactions with related parties exceeding USD 1,000,000.
The Transfer Pricing Technical Study or supporting documentation must be prepared prior to filing the Transfer Pricing Information Return and the Income Tax Return. However, the taxpayer is only required to submit transfer pricing documentation upon request by the tax authority (SAR).
Furthermore, failure to comply with transfer pricing obligations will be penalized in accordance with the regulations, which establish a fine of 10,000 U.S. dollars.