Transfer pricing is an opportunity to improve intercompany operations in an efficient and transparent manner.

We are experts in transfer pricing in Latin America.

Comply with the transfer pricing regulations of each country in which you operate. Our multidisciplinary team will ensure compliance with the arm’s length principle and support you in optimizing your operation.

A comprehensive transfer pricing solution, with personalized attention and constant support to achieve your objectives.

The challenges of determining and documenting your transfer pricing strategies are increasing every day. Tax regulations are increasing in complexity and penalties for non-compliance can seriously affect your company’s profitability and reputation.

Let us optimize your intercompany transactions for the benefit of your business.

What are transfer pricing?

They are defined as the values or prices established by related entities that are part of the same economic group, to transfer or trade goods, services or other rights between them.

To identify the compliance of a company, the risks, functions and assets of
each of its entities are analyzed.

Transfer pricing compliance applies even when there are transactions between companies of the same economic group without monetary consideration. In other words, even when there is no economic value consigned for a service or exchange of goods, the tax must be complied with and paid based on the arm’s length principle. This is one of the biggest challenges for taxpayers around the world.

What is the purpose of transfer pricing?

To verify compliance with the arm’s length principle in transactions between related parties. This makes it possible to demonstrate whether intercompany transactions are carried out under the same conditions as those that would have occurred between independent third parties, with comparable transactions under similar conditions.

The Organization for Economic Cooperation and Development (OECD) plays an important role. It actively participates in the elaboration of general principles and guidelines to define procedures, best practices and relevant documentation that should be taken into account by economic groups to support transactions between related parties.

These guidelines are also binding for the Tax Administrations, thus partially leveling possible subjectivities in auditing processes of a highly technical subject.

How do I know if the transfer pricing obligation applies to me or not?

The legal system of each country establishes the scope of application for companies that carry out operations with related entities.

Each company of an economic group must verify compliance with the applicability assumptions in force in its respective regulations.

There are three types of linkage:

  • Legal relationship,
  • Economic linkage, and
  • Presumptive linkage, which results from the internal rules of each country’s legal system.

There are 3 general duties to be taken into account in the case of being subject to transfer pricing rules under local rules

In case your entity is subject, by local rules, to the transfer pricing rules of the jurisdiction, it is of utmost importance to verify whether the legal system of the country where the entity is located requires the preparation and submission of:

Transfer Pricing Information Statement

It must be submitted to the tax authorities with a summary of the transactions carried out by the entity with its related parties during the tax period under analysis.

Each country establishes in its regulatory framework the specific date on which the return must be filed, as well as the information it must contain, so the scope of data requested depends on each jurisdiction.

Transfer Pricing Report

It is part of the supporting documentation to support the transfer pricing evaluation that has been performed for transactions carried out with related parties.

It contains qualitative information regarding general aspects of the entity and the economic group. Specific information on transactions is detailed in the regulatory framework of each jurisdiction.

Master File

In addition to the two previous points, there are countries where, when the scope of application of transfer pricing is fulfilled, the obligation to submit a Master Report is also activated, which requests qualitative information of the economic group, according to the three-level approach suggested by actions 8, 9, 10 and 13 of the BEPS actions, applicable when the country is a signatory member of the Inclusive Framework to avoid shifting tax bases from one country to another.

We integrate a wide technical knowledge in the field, which guarantees a work with the highest quality standards.

Diagnosis of

We take care of the documentation that gathers functions, risks and assets of the economic group, associated to the value chain and its income attribution policies.

Transfer Pricing Study

They comply with the information required by the regulations in force in each country, demonstrating the free competition compliance of its operation.

Transfer Pricing Policy Development

Having defined transfer pricing policies in place ensures that you are complying in a manner that is appropriate and optimal for your business.

Quality Check

(Sanity Check)

We verify and detect, both in what is included and what is omitted in your transfer pricing analysis and documentation, your areas of weakness/risk as well as opportunities for improvement in the documentation and management of the matter.

Preparation or update of the Master File

We take care of the documentation that gathers functions, risks and assets of the economic group, associated to the value chain and its income attribution policies.

Support in
External Audit

We attend the requirements that the external auditors of the company, or the competent authorities, make regarding transactions with related parties and their transfer pricing studies required by local legislation.

Support in
Legal Processes

We support the legal teams in the processes of representation and litigation of transfer pricing, through the technical support that allows the proper defense of the interests of economic groups with multinational transactions.

Preparation and filing of transfer pricing declarations in different jurisdictions

We collaborate with your company in the preparation of the necessary information to file the Transfer Pricing Declaration according to the local legislation, assisting both in the information as well as in the process of filing the declaration.

Compliance with established regulations
Country by country Report

We prepare your country by country report when you exceed the annual income limits, according to BEPS 13 regulations.

Manage your transactions with related entities efficiently. Learn about the country-by-country approach to transfer pricing.


Article 260-5 of the Tax Statute indicates that as part of the supporting documentation, taxpayers must have a local report that includes information on each type of transaction, and must also have a master report with relevant global information of the multinational group. Both reports must be submitted to the Tax Administration within the deadlines published each year.


Article 762-J of the Tax Code that the persons obliged to file the report (Form No. 930) must have a transfer pricing study with the detail of the information and analysis performed. It must not be submitted on a specific date, but must be delivered in case of receiving a requirement from the General Revenue Directorate within 45 days after the notification.


Article 103 of the Tax Agreement Law establishes that, at the time of filing the income tax return, they must have the information, documents and analysis corresponding to the valuation of transactions with related parties. There is no date in which it must be delivered, however, it is indicated that the documentation must be provided within 10 business days.

Costa Rica

Article 1 of Resolution DGT-R-49-2019 mentions that all taxpayers carrying out transactions with related companies must keep supporting documentation of how the transfer prices comply with the arm’s length principle, as well as the structuring of the economic group at national and international level.


Article 32 of Agreement 027-2015 stipulates that taxpayers subject to the scope of application of the Transfer Pricing Regulation Law shall provide a study on this matter to the Executive Directorate of Revenue. The date of submission, it is stated in Article 29 that it must be delivered when required within the term expressed in Article 48 of the Tax Code.


The transfer pricing statement corresponds to an Annex of the Annual Income Tax Affidavit and therefore it is filed on the same date. Article 65 of Governmental Agreement 213-2013 indicates that the report must present sufficient information and analysis that demonstrates and justifies the adequate determination of the prices or profit margins of the transactions carried out with related parties.


Article 76 of the Income Tax Law establishes that taxpayers who obtain the income indicated in that Title must “obtain and keep the supporting documentation, in the case of taxpayers who enter into transactions with related parties, with which they demonstrate that the amount of their income and deductions were made”.

El Salvador

Article 147, paragraph e) of the Tax Code establishes that taxpayers must keep in good order and condition, for a period of 10 years, the documentation and evidence of transactions with “related parties”. The transfer pricing study is part of the supporting documentation available to the taxpayer.

Dominican Republic

Article 4 of Decree 256-21 mentions that taxpayers subject to the transfer pricing regime must file in electronic format (within 180 days after the filing date of the DIOR), the local study or report. Additionally, Article 4 also refers to a “Master Report” for some taxpayers.

We have more than 35 years of experience in multiple business, tax, transfer pricing and technology issues.

Let us be your strategic partner.

In Grupo Camacho International we help you manage your business efficiently, through our interdisciplinary team of professionals from different areas. If you have any questions, do not hesitate to contact us.