On January 12, 2026, the OECD announced that Guatemala had become the 148th member of the OECD/G20 Inclusive Framework on BEPS (Base Erosion and Profit Shifting), making it the third Central American country to join this international tax cooperation platform. Guatemala’s Ministry of Public Finance confirmed the accession the following day in an official statement, describing it as a historic milestone for the country. The news has a direct technical implication regarding Transfer Pricing that has received little attention until now: membership requires Guatemala to implement the four minimum standards of the BEPS Action Plan, including Action 13, which establishes the three-tier documentation standard—Local File, Master File, and Country by Country Report—which the country had not previously required in its entirety.
What Guatemala Has Committed to Implement
Joining the Inclusive Framework is not a symbolic gesture: it entails a commitment to implement the four minimum standards of the BEPS package, which include combating harmful tax practices (Action 5), preventing the abusive use of tax treaties (Action 6), improving transparency through the Country by Country Report (Action 13), and making cross-jurisdictional dispute resolution mechanisms more effective (Action 14). Of these four, Action 13 has the most immediate and concrete impact on the Transfer Pricing documentation that companies operating in Guatemala must prepare.
Why this contrasts with the regime that existed until now
Prior to this accession, Guatemala differed from most countries in the region precisely because it did not require the filing of a Master File or a Country by Country Report, limiting its formal Transfer Pricing obligations to the analysis and documentation of local transactions with related parties under Decree 10-2012. Until now, this represented a comparatively lighter administrative burden compared to countries such as Mexico, Peru, Colombia, or Argentina, which already require all three levels of the Action 13 standard. With Guatemala’s accession to the Inclusive Framework, this difference will no longer be sustainable in the medium term: Guatemala expressly committed to implementing the minimum standard of Action 13, which, based on the experience of other jurisdictions that have joined the Inclusive Framework, has meant the introduction—within one to three years—of the obligation to file the Master File and Country by Country Report for multinational groups that exceed the corresponding revenue thresholds.
What Multinational Groups with Operations in Guatemala Should Anticipate
For a multinational group currently operating in Guatemala under the assumption that the country only requires Transfer Pricing documentation at the local level, joining the Inclusive Framework is a clear signal that this simplified regime has a limited lifespan. The experience of other Central American countries that previously joined the Inclusive Framework—and subsequently introduced their own Master File and Country by Country Report requirements, as has recently occurred in Costa Rica—suggests that Guatemala will follow a similar path. Groups with parent companies outside Guatemala that already prepare Master Files and Country by Country Reports for other jurisdictions should begin assessing whether that same documentation will need to be adapted to meet a potential formal requirement from the Guatemalan Superintendency of Tax Administration (SAT) in the short- or medium-term.
At TPC Group, we are monitoring regulatory developments in Guatemala following its accession to the Inclusive BEPS Framework, and we are working with our clients operating in the country to assess how to prepare for a potential expansion of their Transfer Pricing documentation obligations to the full three-tier standard of Action 13.
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