Source & more info: Ernst & Young
Tuesday, 8 May 2012
El Salvador issues Transfer Pricing Guidelines
On 23 March 2012, the Dirección General de Impuestos Internos ("DGII") issued Administrative Guideline No. DG-001/2012, intended to provide general guidance to taxpayers on the tax treatment of related party transactions or transactions with entities domiciled in tax havens jurisdictions. In 2009, the Salvadorian Tax Code ("TC"), was modified through Decree No. 233, which included among the relevant changes the introduction of new transfer concepts such as the definition of the arm’s length principle and comparability (along with the criteria for establishing it), and the definition of related parties, which includes tax havens.