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HONDURAS: LAUNCH OF THE SAR VIRTUAL OFFICE

Following the launch of the new Virtual Office in May 2024, the old DET Live system will be replaced.

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DOMINICAN REPUBLIC: IMPLEMENTATION OF COUNTRY BY COUNTRY REPORTING AND OECD STANDARDS

The Dominican Republic continues to take firm steps towards aligning its Transfer Pricing obligations with OECD standards.

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CHILE FOCUSES ON TRANSFER PRICING. NEW CRITERIA TO DEFINE A CASE AS RELEVANT OR OF INSTITUTIONAL INTEREST (EXEMPT RESOLUTION SII N°120)

This Resolution issued by the Internal Revenue Service (SII, from Spanish) in December 2024 places special emphasis on Transfer Pricing (TP) and is aligned with Tax Compliance Law N° 21.713 of September 25, 2024, which provides new tools to the SII to combat informality, evasion, avoidance, and organized crime.

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BRAZIL ENHANCES TRANSPARENCY IN COMMODITY TRANSACTIONS WITH NEW TRANSFER PRICING REGULATIONS

The Brazilian Federal Revenue Service (Receita Federal, RFB) has issued Normative Instruction RFB No. 2,246/2024, which amends the previous regulations on Transfer Pricing (TP) in commodity transactions between Brazilian companies and related parties abroad. This new regulation, which comes into effect on January 1, 2025, aims to ensure that transfer prices align with market practices and the arm’s length principle.

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HONDURAS: IMPLEMENTATION OF THE COUNTRY-BY-COUNTRY REPORT (CBCR)

The Country-by-Country Report (CbCR) will come into effect in Honduras for fiscal years ending on or after January 1, 2025.

On March 19, 2024, the Tax Administration Service (SAR, from Spanish) announced the guidelines for the submission of the Country-by-Country Report by multinational companies with tax residence in Honduras, whose consolidated revenues  exceeds the threshold of 750 million euros, through Agreement SAR-653-2023.

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GUATEMALA: THE SAT IS PAYING SPECIAL ATTENTION TO TRANSACTIONS BETWEEN LOCAL RELATED PARTIES

Lately, the Superintendence of Tax Administration (SAT, from Spanish) has been focusing on transactions between local related companies.

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COLOMBIA: EXECUTIVE ORDER 1,496 OF 2024 MODIFIES THE LIST OF NON-COOPERATIVE AND LOW OR NON TAXATION JURISDICTIONS

On December 13, 2024, the Colombian Ministry of Finance and Public Credit published the Executive Order 1,496 of 2024, modifying the list of non-cooperative and low or no taxation jurisdictions in Colombia.