The Ministry of Finance and the General Directorate of Taxation have submitted for comment the draft resolution on the tax obligation on transfer pricing. Comments on the draft shall be submitted between February 12 and 26, 2025.
This draft resolution establishes the mandatory filing of the annual informative transfer pricing statement for taxpayers engaging in domestic or cross-border transactions with related parties and classified as large national taxpayers, or individuals or entities under the free trade zone regime, whose transactions whether separately or collectively, exceed the amount equivalent to one thousand base salaries in the fiscal year, as applicable.
The deadline for fulfilling this obligation shall be within three months following the end of the tax year, and the informative statement shall be filed using the form provided by the General Directorate of Taxation via the virtual platform TRIBU-CR.
Failure to comply with the submission of the statement will result in the imposition of the penalty described in Article 83 of the Tax Code of Rules and Procedures.
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