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Fines for non-compliance with transfer pricing reporting start to be applied

The Directorate General of Revenue (DGI) is constantly notifying resolutions imposing 1% fines to taxpayers who fail to submit the "Transfer Pricing Report" and/or are late. Learn how to avoid these fines and be up to date.


Article 762-I of the Tax Code establishes a fine of 1% of the total amount of related party transactions, up to a maximum of one million dollars, in cases of omission and/or untimely filing by taxpayers of the "Transfer Pricing Report" with the General Revenue Directorate (DGI) of the Ministry of Economy and Finance. This report is scheduled to be due within six months after the closing date of the fiscal period, i.e. 30 June for taxpayers with regular fiscal years.


The Directorate General of Revenue (DGI) is constantly notifying resolutions imposing 1% fines on taxpayers who fail to submit and/or are late in submitting the "Transfer Pricing Report" in accordance with the Tax Code. The DGI has penalised those taxpayers who have recorded their transactions with related parties in their Income Tax Returns, but failed to file the report.


It may also happen that a non-compliance is detected using cross-checks of information from the different returns through the E-Tax 2.0 system or in an audit process of the same taxpayer or a local related taxpayer.


In cases of omission, in addition to the 1% penalty, the rulings request the submission of the "Transfer Pricing Report" within a period of (15) business days.


Failure to file the report in accordance with the provisions of the resolutions would lead to an additional fine of $1,ooo.oo to $10,000.oo and up to a possible closure of the establishment.


Full note at: https://www.martesfinanciero.com/voz-calificada/comienzan-a-aplicar-multas-por-incumplir-informe-de-precios-de-transferencia/

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