Since 2016, the Treasury Department established the obligation to file the information Transfer Pricing statement and the Transfer Pricing study. Subsequently, in 2018, the Country-by-Country reporting was included within these obligations.
Documentation to Be Filed
- Local Report
- Master File
- Country-by-Country Report
According to Resolution DGT-R-49-2019, taxpayers must have an informative report of the local company (Local Report) and a corporate information report (Master File), as per BEPS Action 13 on supporting documentation on the matter. Likewise, the Country-by-Country Report shall only be filed within the 12 months following the closing date of the corresponding tax period.
Submission
The Transfer Pricing Studies must only be filed to the General Directorate of Taxation (GDT) when formally required by the institution.
General Directorate of Taxation (GDT)
Information Transfer Pricing Statement
Article 3°. -Periodicity. The term for filing the Transfer Pricing statement expires on the last business day of June of each year, including all the transactions carried out during the profit tax period authorized by the taxpayer immediately preceding.
No later than the last business day of June 2017, the information statements corresponding to the periods 2015 and 2016 must be filed simultaneously. Subsequently, the statement containing the information for the immediately preceding tax period must be filed each year.
The filing deadline for the information Transfer Pricing statement established in Article 3° of Resolution DGTR-44-2016 of eight o’clock on August twenty-sixth, two thousand sixteen is suspended until the Tax Administration communicates the date and means to file the information Transfer Pricing statements, according to Article 1 of this resolution.
Until such time as the Tax Administration provides the electronic means to file the information Transfer Pricing statement, the taxpayers shall keep the information corresponding to such statement and, when individually required, shall make it available to the Tax Administration.
Source: SCIJ / Grupo Consultor Efe
