April 30, 2025 is the deadline for certain taxpayers in Honduras to file Form 545 of the Informative Affidavit on Transfer Pricing (DJIAPT), corresponding to the 2024 fiscal year, as established in Article 31 of the Regulations of the Transfer Pricing Law.
Who should file Form 545 of the DJIAPT?
The obligation to file this return applies to:
- Natural or legal persons classified as medium or large taxpayers who carried out commercial or financial transactions with related or linked parties.
- Natural or legal persons who carried out transactions with entities under special tax regimes that enjoy tax benefits.
- Natural or legal persons who carried out commercial or financial transactions with related parties resident in tax havens.
- Small taxpayers who carried out transactions with related parties for an amount exceeding US $1,000,000 or its equivalent in lempiras.
What transactions should be reported?
All commercial and financial transactions carried out with related parties must be reported, as well as those carried out with natural or legal persons domiciled in special tax regimes with tax benefits, during the corresponding tax year. The objective is to ensure that these transactions are carried out at market prices, in accordance with the arm’s length principle.
Deadlines for submission
According to Article 31 of the Regulations of the Transfer Pricing Regulation Act (LRPT), the DJ must be filed by April 30 of the year following the fiscal year being reported. For taxpayers with a special fiscal period, the deadline is three months after the end of their fiscal year.
Supporting Documentation
In order to prove that the prices agreed between related parties are at market value, in the event of a review by the Revenue Administration Service (SAR), taxpayers must prepare a technical analysis that must contain at least the following information:
- Description of activities, functions and risks assumed.
- Details of the operations and documents used.
- Identification of related parties.
- Valuation methods used and comparable transactions.
Importance of Compliance
It is essential that taxpayers comply with this obligation to file DJIPT Form 545 in a timely manner to avoid penalties. Failure to comply or the submission of false or incomplete information may result in severe penalties.
In order to fill in this affidavit correctly, it is essential to have the Local File corresponding to the operations of the fiscal period being reported and to support the analyses carried out.
To ensure proper compliance with this obligation and avoid possible penalties, taxpayers are advised to review their related party transactions in detail and prepare the necessary documentation in advance.
Source:
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Transfer Pricing Regulatory Law Decree 232-2011.
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Regulations of the Transfer Pricing Regulatory Law Agreement 027-2015.
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Agreement DEI–SG–004.