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.
With an emphasis on fiscal transparency and adherence to international standards to prevent base erosion and profit shifting (BEPS), it was established that the CbCR must be submitted by entities that are the Ultimate Parent of the multinational group, or in cases where they are not, those entities will be required to submit the report if the Ultimate Parent is not required to do so in its jurisdiction, or if its jurisdiction does not have an information exchange agreement with Honduras. Additionally, those entities will need to submit the report if they have been notified of a systematic failure to exchange information.
The deadlines for submitting information are as follows:
- CbCr submission deadline: A maximum period of 12 months from the last day of the fiscal year of the Ultimate Parent Entity.
- Prior notification: No later than December 31 of the reportable fiscal year, the SAT must be notified if it is an Ultimate Parent Entity or the details of the Reporting Entity.
As specialists in the field, we can assist you with this matter and any other concerns related to Transfer Pricing in the region.