Transfer Pricing Trends in Honduras and Central America

August 28, 2024

Regional Transfer Pricing Overview in Central America  

Transfer Pricing regulation in Central America has gained prominence in recent years, with several countries implementing robust legal frameworks to control transactions between related companies. Honduras and its neighboring countries, such as Guatemala, El Salvador, and Costa Rica, have adopted specific measures to ensure that the pricing of related party transactions is under market conditions. This overview demonstrates more transparency and tax control in the region, intending to avoid tax base erosion and ensure fair tax collection.   

Regulatory Comparison: Honduras vs. Guatemala, El Salvador and Costa Rica  

Although most Central American countries follow OECD guidelines, there are several differences in the implementation and approach to Transfer Pricing regulations. For example, these regulations are relatively new in Honduras, challenging the tax administration and companies. Guatemala and El Salvador have adopted more traditional approaches, while Costa Rica has adopted a model more aligned with international best practices. 

This comparison demonstrates how each country balances the need for tax control by promoting a favorable environment for foreign investment. 

Challenges and Opportunities for Companies in the Region  

Companies operating in multiple Central American jurisdictions face the challenge of complying with different Transfer Pricing requirements, which can increase complexity and compliance costs. Conversely, this regulatory diversity also offers opportunities to optimize tax structures and take advantage of regulatory differences. Companies can benefit from understanding the particularities of each country and aligning their Transfer Pricing strategies to reduce tax risks and maximize operational efficiency.   

Future Prospects: Regulations Direction 

The Central American trend directs toward greater harmonization of Transfer Pricing regulations influenced by the OECD recommendations and increases cooperation among these regional tax authorities. Eventually, more countries shall strengthen their regulatory frameworks and adopt stricter approaches to control related party transactions. These regulatory developments present challenges and opportunities for companies, which will have to adapt quickly to the changes to remain competitive and meet their tax obligations.   

Call to Action

Is your company prepared for tax challenges in Central America?   

At TPC Group, we offer customized solutions to assist you in complying with Transfer Pricing regulations throughout the region.  Contact us today and ensure the success of your tax strategy!  

Source:  This analysis is based on review of Central American countries' tax legislations, OECD Transfer Pricing reports and regional tax audit reports.