Panama amends transfer pricing legislation

Tax Insights ()

The Tax Administration introduced amendments in the transfer pricing legislation in order to make it effective to all intercompany transactions with foreign related parties without considering where they are domiciled. During fiscal year 2011, the requirement was only limited to those transactions with related parties located in jurisdictions where Panama has a Double Taxation Treaty in place. Additionally, the 52 act of 2012 establishes that the obligation to document will be required for transactions carried out from fiscal year 2012 and the respective informative return will be filed for the first time within six months after the taxpayer’s fiscal year end.