April 30, 2025, is the deadline for certain taxpayers in Honduras to file Form 545 of the Annual Informative Transfer Pricing Affidavit (AITPA), corresponding to the fiscal year 2024, as established in Article 31 of the Transfer Pricing Regulation Law.
Who Must File the AITPA Form 545?
The obligation to file this statement applies to the following:
- Individuals or legal entities classified as medium or large taxpayers who performed commercial or financial-related party transactions.
- Individuals or legal entities who performed transactions with entities under special tax regimes with tax benefits.
- Individuals or legal entities who performed commercial or financial transactions with related parties resident in tax havens.
- Small taxpayers who performed related party transactions exceeding US $1,000,000 or its equivalent in lempiras.
Transactions to Be Reported
All commercial and financial related party transactions and those performed with individuals or legal entities domiciled must be reported in special tax regimes with tax benefits during the corresponding fiscal year to ensure that these transactions are at market prices, according to the Arm’s Length Principle.
Filing Deadlines
According to Article 31 of the Transfer Pricing Regulation Law, the affidavit must be filed by April 30 of the year following the fiscal year reported. The deadline for taxpayers with a special tax period is three months after the fiscal year-end.
Supporting Documentation
In order to evidence that the prices agreed among related parties are at market values before an eventual review by the Revenue Administration Service (RAS), taxpayers must prepare a technical analysis containing the following information as a minimum:
- Description of activities, functions, and risks assumed.
- Details of the operations and documents used.
- Identification of related parties.
- Appraisal methods employed and comparable operations.
Compliance Relevance
Taxpayers must comply with this obligation to file the AITPA Form 545 in due time and form to avoid penalties. Failure to comply or misreporting false or incomplete information may result in severe penalties.
For filling this statement correctly, a Transfer Pricing study corresponding to the operations of the tax period being reported and supporting the analysis performed is indispensable.
To ensure compliance and avoid penalties, taxpayers should thoroughly review their related party transactions and prepare the necessary documentation in advance.
Source: Transfer Pricing Regulatory Law Decree 232-2011. / Regulations of the Transfer Pricing Regulatory Law Agreement 027-2015. / Agreement DEI–SG–004.