The deadline for submitting the "Transfer Pricing Report" is 30 June. The penalty for omission or late filing is 1% of the total amount of the transactions.
The deadline for filing the "Transfer Pricing Report" (Form 930) with the Directorate General of Revenue (DGI) is 30 June for those taxpayers with a regular period who entered into transactions with related parties during the 2021 tax period. It is important to note that the omission and/or untimely filing of this report establishes a penalty of 1% of the total gross amount of the transactions with related parties, and may reach a fine of $1,000,000.00 in accordance with the provisions of Article 762-I of the Tax Code.
The amounts of income, costs and expenses with related parties reported in the Sworn Income Tax Return should, in principle, match the amounts declared in the Transfer Pricing Report. On occasions, the Directorate General of Revenue has requested taxpayers to submit a rectification of the Sworn Income Tax Return due to these inconsistencies, affecting the statute of limitations of the tax obligation.
Recently, in the Sworn Income Tax Returns, new boxes were incorporated corresponding to the obligation to report transactions with local related parties pursuant to Article 762-L of the Tax Code, provided that at least one of the parties is located in the Free Zones, Free Trade Zones, Special Economic Areas and Special Regimes in Panama.
In addition to complying with the deadline for filing the report to avoid formal sanctions and to seek to maintain consistency in the amounts of transactions declared, taxpayers should be aware of the importance of the data contained in the report to ensure its proper filing and mitigate tax risks. The Directorate General of Revenue, through the implementation of the Transfer Pricing Report version 2.0, has been working on the quality of the data provided in this report for the cross-referencing of tax information.
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