Publications
Country-by-Country Report: Honduras
The scope of this obligation to file the Country-by-Country Report in Honduras will apply when the jurisdiction where the ultimate…Affidavit Regarding Transfer Pricing in Honduras
In accordance with Article 30 of the Transfer Pricing Regulation Act, taxpayers who engage in transactions with related parties or…TRANSFER PRICING REGULATIONS IN GUATEMALA
APPENDIX TO THE ANNUAL INCOME TAX RETURN, REGARDING RELATED PARTIES To determine whether a transaction is subject to transfer pricing…
TRANSFER PRICING IN BOLIVIA
Since September 2015, transfer pricing rules have been governed by Law 516 on Investment Promotion, Law 549, or the Law…
Tax Court Ruling: RTF 01428_1_2023
In accordance with the provisions of RTF No. 01428_1_2023, we set forth the Tax Court’s position regarding the analysis of…
Tax Ruling No. 04508-9-2022
Resolution No. 04508-9-2022 outlines the criteria for extraordinary expenses in the application of transfer pricing rules during an international economic…
Tax Court Ruling: RTF 03265-3-2022
A review of RTF 03265-3-2022 reveals the Tax Court’s position regarding the classification of various financing mechanisms (capital contributions or…
Ecuador: SRI Updated the Technical Guidelines for Standardizing Transfer Pricing Analysis
On November 22, 2023, the Internal Revenue Service (SRI) published an updated version of the “Technical Guidelines for the Standardization…
Transfer Pricing Requirements in Colombia for the 2023 Period
Who is required to file the Master File and Country-by-Country Reports in Colombia for the 2023 reporting period? Master File:…
Process for Applying Amount A Under Pillar I
The OECD’s proposals under Pillar I seek to revise the allocation of the tax base in a digitalized and global…
