Transfer Pricing in Guatemala

A new approved law aims to regulate transfer pricing, but detailed rules are still missing.

Monday, December 3, 2012 reports that "In Guatemala the regulation of the transfer pricing has been approved as part of the tax update package, according 10-2012, to try to prevent related companies (parent and subsidiaries, for example) from manipulating prices when exchanging goods or services, so that they increase their costs or deductions in order to reduce taxes. "

"Transfer prices are the payments made by multinationals to another part of the same company for goods purchased or services rendered, however this process can include income tax, customs and value added tax evasion" .. because a transnational corporation "could sell to one of its subsidiaries more expensively or cheaply than the price that should be settled in a fully competitive market, depending on the strategy of accumulating assets so as to reduce tax payments."

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More on this topic

SAT Asks for Transfer Pricing Study

October 2015

Legislation on the obligation to submit transfer pricing studies is beginning to be applied in concrete by the Tax Authority.

In his article on, Mario Coyoy describes the requirements for taxpayers being developed by the SAT:

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1. Sufficient information and analysis (Study on Transfer Pricing) to demonstrate and justify the correct pricing, the amount of the consideration or profit margins in transactions with related parties abroad.

Honduras: Transfer Pricing Law Comes Into Effect

July 2015

It has been announced that in August the regulations governing transfer pricing will take effect and penalties will be imposed of $10 thousand to $20 thousand on companies that do not submit a declaration.

Companies that do not submit a declaration after three months after the entry into force of the regulations are subject to fines ranging between $10 thousand and $20 thousand.

Transfer Pricing in Costa Rica

July 2013

The regulation currently being processed aims to regulate the sale prices of goods and services between related companies.

"... the Executive power has introduced a bill, which is being processed by the legislation, called the Law on Control of Fiscal Evasion, which includes a chapter on this subject, which is virtually a decree, with the addition of specific sanctions for breaches of duties set out in the bill," says Ana Elena Carazo in

Justifying Transfer Pricing Becomes Mandatory

January 2013

According to the new Law on Income Tax, companies based in the Guatemalan territory will have one year from January 1 to justify the amount of their operations.

According to the Tax Authority (SAT), the transfer pricing audits will begin in April 2014, where they oversee if taxpayers filed within the prescribed time and in the formats provided their annual income on their tax return.