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Transfer Pricing

In January 2013, the new Income Tax Law included in Book I of the Tax Law Update went into effect, which included for the first time in Guatemala "Special Valuation Rules between Related Parties;" that is, Transfer Pricing regulations.  In May 2013, the Income Tax Regulation, which contains extensive regulations on this matter, was published.

After the Transfer Pricing rules had been in effect and applicable from January 1st to December 20, 2013, Decree 19-2013 of the Congress of the Republic was published on that last date.  Such decree suspended the validity and application of the “Special Valuation Rules between Related Parties;” however, they will go back into effect and application as of January 1, 2015.  Notwithstanding the suspension mentioned above, Decree 19-2013 establishes that during such suspension, the Tax Administration may request information from taxpayers regarding Transfer Pricing in order to create the necessary databases.

Under the "Special Valuation Rules between Related Parties” – Transfer Pricing -, transactions of Guatemalan companies with their non-resident related parties that have an impact on the tax basis (income, costs, and expenses) should be valued by observing the Arm’s Length Principle, for Income Tax purposes.

Due to the above, and in order to face the challenges of this regulation, our firm can currently provide your company with the following services:

  • Advisory services for complying with the Transfer Pricing Regulations
  • Transfer Pricing Diagnosis
  • Tax Planning under Transfer Pricing
  • Transfer Pricing Study
  • In-house training on Transfer Pricing
  • Support with requests from the SAT regarding Transfer Pricing, and
  • Advanced Pricing Agreements with the Tax Administration.
Byron Martinez             Partner bymartinez@deloitte.com
Mario Roberto Coyoy    Director mcoyoy@deloitte.com
Yuetyin Jovita Jo C.      Acting Manager  jovita.jo@deloitte.com
Oscar Raúl Gracias       Senior ogracias@deloitte.com