The General Directorate of Internal Taxes has published a Guidance for the 2025 Fiscal Year, aimed at facilitating compliance with obligations regulated in the Tax Code. The objective is to help identify countries, states, or territories that have preferential tax regimes with low or no taxation.
Regarding Transfer Pricing (“TP”), entities located in territories with preferential tax regimes are considered related parties. This means that transactions with such entities must comply with TP regulations, ensuring they are conducted at market value.
It is essential for taxpayers to carefully review this Guidance and assess the impact of these provisions on their business operations to ensure compliance with tax obligations and avoid potential penalties.
As specialists in the field, we are available to assist you with this matter and any other inquiries related to Transfer Pricing in the region.