Through Resolution No. 201-5949, published on June 26, 2023, the General Revenue Directorate of Panama extended the deadline to file the “Transfer Pricing Report” or “Form 930” for the period 2022. On June 30, 2023, the deadline to file the Form expired but was extended until July 14.
1. Obligated Parties to File the Transfer Pricing Report
According to Article 762-I of the Tax Code, taxpayers entering into transactions with related parties residing abroad will be obligated to file the Transfer Pricing Report or Transfer Pricing Affidavit through Form 930.
2. Non-compliance Penalties
The General Revenue Directorate applies a fine of 1% of the total amount of related-party transactions for failure to file Form 930, being able to reach up to $1 million. On the other hand, the General Revenue Directorate is applying fines for erroneous content in the Transfer Pricing studies.
3. Increasing Imposition of Fines
Throughout the year, the application of fines in those local transactions in which one of the parties is located in free trade zones, special economic areas, and special regimes, and those not subject to obligations until 2019, has increased.
Therefore, this extension prevents taxpayers from penalties stipulated in the Tax Code.
Source: Martes Financiero 06/30/23
