Global Tax Alert (News from Transfer Pricing and Americas Tax Center) | 14 March 2014

Guatemala Tax Administration confirms transfer pricing compliance for 2013

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On 11 March 2014, the Guatemala Tax Administration (Superintendencia de Administración Tributaria or SAT) issued an announcement in the Publinews gazette, affirming the obligation for taxpayers to comply with the transfer pricing regulations for the 1 January 2013 to 20 December 2013 period. This clarifies the requirements in the wake of the issuance of Decree 19-2013 on 20 December 2013 in which transfer pricing regulations were postponed in Guatemala to become effective as of 1 January 2015.

The communication states that during the mentioned period all cross-border related party transactions conducted by taxpayers under the “regime on profits from profitable activities” and under the “optional simplified regime on revenue from profitable activities” are subject to specific transfer pricing regulations and the SAT is empowered to request the documentation study and adjust prices when taxpayers do not comply with the arm’s length principle.

For additional information with respect to this Alert, please contact the following:

Mancera, S.C., Mexico City and Central America
  • Jorge Castellón
    +52 55 5283 8671
    jorge.castellon@ey.com
Ernst & Young, S.A., San José, Costa Rica
  • Rafael Sayagues
    +506 2208 9880
    rafael.sayagues@ey.com
Ernst & Young Limited Corp., Panama
  • Luis Eduardo Ocando
    +507 208 0144
    luis.ocando@pa.ey.com
  • María José Luna
    +507 208 0147
    maria.luna@pa.ey.com
Ernst & Young, S.A, Guatemala City
  • José Echeverría
    +502 2386 2403
    jose.echeverria@pa.ey.com

EYG no. CM4263