NewsFlash April

Upcoming Transfer Pricing Deadlines in the Americas    

Argentina: May 31st (2nd Country-by-Country Report Notification, for companies whose UPE* files the Country by Country Report in 03/23).   

Bolivia: May 2nd (extension to May 31st) (Informative Statement (F.601) and Local Report (companies with and without accounting records and free professions, and carriers)). 

Honduras: May 2nd (Informative Declaration DIAPT). 

Mexico: May 15th (Annex 9 of the DIM, Annexes of PT of the Tax Return, Local Report). 

Dominican Republic: May 2nd (DIOR Informative Declaration (FYE** 12/22, accounting closing of the local company), Master Report and Local Report (FYE 06/22)). 

 * Ultimate Parent Entity 

** Fiscal Year Ending.  


Argentina: tax authority modifies the definition of beneficial owner for trusts    

The Federal Administration of Public Income (AFIP in Spanish), by means of General Resolution 5337/2023, modified the definition of beneficial owner for trusts established by General Resolution 3312. The new definition establishes that if the resident or non-resident trust has shares or quoted units, the report must identify the persons who own at least, either directly or indirectly, 2% of the capital as of December 31st of the reporting year. The previous rule additionally established an alternative monetary threshold of ARS 50 million, which was eliminated.     

The resolution simplifies this rule and keeps the other conditions unchanged. The measure was published in the Official Gazette on March 30th, 2023, and is effective as from that date.  

To consult the resolution, click here. 

 Costa Rica: the tax administration delays the deadline for filing the beneficial ownership declaration  

Through Resolution No. MH-DGT/ICD-RES-0004-2023, the General Directorate of Taxation (DGT) has extended the deadline for filing the beneficial ownership declaration (applies only for the 2023 tax return). For the following years, the filing deadline will continue to be in April. 

The resolution also allows taxpayers to file corrections to their return at any time during the reportable period. Previously, corrections were only allowed in the month following the filing deadline. The resolution was published in the Official Gazette on March 22nd, 2023, and is effective as of that date.  

To consult the resolution, click here. 

Ecuador – South Korea: Strategic Economic Cooperation Agreement (SECA) 

Negotiations for the Strategic Economic Cooperation Agreement (SECA) between Ecuador and South Korea took place from April 3rd to 7th, 2023.    

This agreement will increase non-oil exports between the two countries.  

After the closing of the negotiations, some aspects are still pending before signing the agreement, such as the translations of the text and the legal review. Likewise, the document must be validated by the Constitutional Court and approved by the National Assembly (parliament) for its entry into force.  Further developments will be reported as they occur.  

For more details, click here. 

Panama: tax authority allows taxpayers to request extensions when claiming tax treaty benefits  

The General Revenue Directorate (DGI), through Resolution 201-2232, granted taxpayers the ability to request extensions of time to rectify errors or missing documentation during the application for benefits under double tax treaties.   

A taxpayer may request the benefits established in any tax treaty by submitting a formal request to the DGI 30 days prior to the execution of the transaction. The DGI has a maximum term of two months to respond to the corresponding request, provided that the documentation submitted by the taxpayer is complete and correct.   

The resolution grants taxpayers the option to request a maximum of three extensions of time (of two months each) to correct or complete any missing documentation identified by the DGI. If the taxpayer does not correct the identified deficiencies, once the extension has been exhausted a resolution will be issued denying the requested benefit. 

The resolution was published in Official Gazette No. 29754 on April 4th, 2023, and is effective as of that date.  

To consult the resolution, click here. 

Paraguay: OECD publishes updated Transfer Pricing country profile 

On April 11th, 2023, the OECD (Organization for Economic Co-operation and Development) published an updated country profile on Transfer Pricing in Paraguay.  

This document provides valuable information on Paraguay’s national legislation on key transfer pricing principles. This information is intended to reflect the current state of Paraguay’s legislation and to indicate the extent to which its rules follow the OECD Transfer Pricing Guidelines. 

To consult the document, click here. 


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