NewsFlash March 2024

Upcoming Transfer Pricing Deadlines  

Bolivia: April 30th

  • F.601- Informative Declaration and Local Report for banking, insurance, commercial and service companies, companies with and without accounting records, carriers, and independent professionals.  

United States: April 15th

  •  F.5472 – Annual Corporate Income Tax Return for C-Corps (fiscal year ending 12/31/23) – *six-month extensions are granted, moving the effective deadline to October 15*.

Honduras: April 30th

  •  Annual transfer pricing information affidavit. 

 Chile: first ruling on application of the General Anti-Circumvention Rule 

The Tax and Customs Court of the Bíobío and Ñuble Regions ruled in favor of the position of the Internal Revenue Service (SII) in finding that Forestal Aurora SpA, a taxpayer in the forestry sector, had used unfair practices to reduce its tax burden, which constitutes tax avoidance. This ruling is the first to apply the General Anti-Circumvention Rule.  

The court considered that the financial structure created by the company was purely for tax purposes and did not have at commercial purpose. The SII highlights that this case is part of an ongoing effort to strengthen tax compliance, reflected in 22 other similar injunctions filed before the Court.  

To read the news, click here.   

 Peru: SUNAT strengthens capacity to audit multinational groups   

In the week of March 18, the National Superintendency of Customs and Tax Administration (SUNAT), in collaboration with the OECD’s Tax Inspectors without Borders Program and the United Nations Development Program (UNDP), began an exchange of experiences to reduce tax evasion and avoidance in Peru.   

The experts involved will address issues related to the management of Country-by-Country Report data and the exchange of information. Likewise, they plan to implement methodologies to evaluate and quantify tax compliance risks in cross-border and intra-group operations, which will help to detect illegitimate tax planning with the information sources available to SUNAT.   

To read the news, click here. 

United Kingdom: plan to include anti-abuse rule in in BEPS Pillar 2 regulations 

 In a ministerial statement issued on March 14, the UK government announced its intention to include an anti-abuse regulation in the BEPS Pillar Two rules. This measure will be formalized in a future Finance Bill. The government plans to hold consultations with stakeholders to ensure that the legislation works as intended and does not generate unintended effects.  

To view the publication, click here. 

European Union: consultation on rules governing the resolution of tax disputes  

On March 12, 2024, the European Commission launched a consultation with the objective of allowing interested parties to provide comments on the rules governing cross-border tax disputes related to double taxation issues (including those relating to transfer pricing) for both companies and citizens.   

The Tax Dispute Resolution Mechanisms (DRM) Directive came into force on July 1, 2019, and established clearer rules and stricter deadlines for addressing these disputes. The deadline to participate in this consultation is May 10, 2024.   

To review the consultation, click here. 

Contact Us 

Please do not hesitate to reach out to us with any questions or comments at



Share this post:

Join Our Newsletter

Sign up to learn more about BaseFirma and how we can help you.

Scroll to Top