NewsFlash June - 2024

Upcoming transfer pricing due dates

?Argentina: June 23 - 29

• Disclosure Form F.2668.
• Local File F.4501 - companies with Fiscal Year Ended 12/31/23.
• Master File - companies with Fiscal Year Ended 06/30/23.

Argentina: June 30

• 1st Notification Country-by-Country Report - Ultimate Controlling Entity with Fiscal Year Ended 03/31/24.
• 2nd Notification Country-by-Country Report - Ultimate Controlling Entity with Fiscal Year Ended 04/30/23.
• Country-by-Country Report - Fiscal Year Ending Ultimate Controlling Entity on 06/30/23.

Canada: June 30

• Disclosure Form T106 - Corporations.

Chile: June 28

• Disclosure Form F.1913 (1907 with Country-by-Country Report Notification).
• Local File F.1951.
• Master File F.1950.
• Country-by-Country Report F.1937.

Panama: June 30

• Disclosure Form F.N930 - companies with Fiscal Year Ending 12/31/23.

Peru: June 18 - 26

• Disclosure Form FV3560.
• Local File.

Uruguay: June 30

• Country by Country Report Notification - Ultimate Controlling Entity with Fiscal Year Ended 06/30/2023.

Venezuela: July 1

• Disclosure Form PT99 - companies with Fiscal Year Ended 12/31/23.

BaseFirma expands its valuation services practice with the hiring of Paul Valdivieso as valuations lead based in Italy

BaseFirma has announced the appointment of Paul Valdivieso as valuations lead, based in Bologna Italy. The addition of a new valuation services lead continues our firm’s expansion of valuation offerings and capabilities across the globe.

Mr. Valdivieso brings over 12 years of extensive experience in valuation projects, transfer pricing advisory, and economic research to BaseFirma’s global practice. Mr. Valdivieso’s valuation and financial transactions transfer pricing expertise will help our clients navigate increasing regulatory scrutiny and fully benefit from BaseFirma’s highly integrated approach.

You can read BaseFirma’s Press Release here.

Albania and Cameroon join agreement for automatic exchange of Country-by-Country Reports

According to an update published by the OECD dated April 30, 2024, both Albania and Cameroon have formally joined the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (CbCR MCAA). Albania joined on March 11, 2024, and Cameroon on January 25, 2024.

The agreement allows for the automatic exchange of Country-by-Country Reports between countries. These reports, which are part of transfer pricing documentation, provide valuable information on the global allocation of income, profits, taxes paid and economic activity of multinational groups to tax administrations.

As of April 30, 2024, the CbCR MCAA has been signed by 103 jurisdictions.

You can consult the OECD’s list here.

Chile: New 3-Month Extension Announced

On June 7, 2024, EX. SII Resolution No. 64 granted a 3-month legal extension for taxpayers to submit the following documentation requirements between July 1 and September 30 of the corresponding year.

• Form No. 1907: Disclosure Form.
• Form No. 1937: Country-by-Country Report.
• Form No. 1950: Annual Master File.
• Form No. 1951: Annual Local File.

It is important to note that Form No. 1913: Annual Global Tax Characterization Disclosure maintains its submission deadline of June 28, 2024.

You can read the resolution here.

Ecuador: resolution issued modifying the penalty regime and new deadlines for filing transfer pricing reports

On May 28, 2024, the Internal Revenue Service (SRI) of Ecuador published resolution NAC-DGERCGC24-00000020, which extends the deadline for filing transfer pricing reports and Disclosure Forms with Related Parties (AOPR for its acronym in Spanish) for the year 2023, until September 2024.

Additionally, it stratifies the types of taxpayers and establishes penalties for non-filing or delivery of incomplete, inaccurate or erroneous information, and for late filing of disclosure forms.

Download the resolution here.

Ecuador: Local guidelines for standardizing transfer pricing analyses

On May 27, 2024, the Internal Revenue Service (SRI) of Ecuador published a new technical file for the standardization of transfer pricing analysis, replacing the one published in November 2023. It establishes the definitive content that would apply for the comprehensive transfer pricing report to be filed for fiscal year 2023.

Download the updated technical sheet for the analysis of the comprehensive report here.

Ecuador updates technical sheet for reporting transactions with related parties

On April 24, the Internal Revenue Service (SRI) of Ecuador published, through its website, an update of the local guidelines for the AOPR.

This update includes clarification on credit and debit notes, specifying that these must be reported on a net basis, and details for four types of transactions:

• Clarifications on credit and debit notes, specifying that these must be reported on a net basis, and details for four types of transactions:
• Revenue 100: export or sale of inventories produced.Revenue 101: export or sale of inventories not produced.Expense 200: import of inventories for production.Expense 201: import of inventories for distribution.
• Clarifications on how to report for certain types of special operations, such as investments or credits during the period.
• New countries were included in the list for preparing the return.

The fact sheet was published on the tax authority's website and went into effect on the day of publication.

Download the updated AOPR schedule fact sheet as here.