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El Salvador Publishes Updated Transfer Pricing Guidelines

19 April 2018

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Approved Changes

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El Salvador

El Salvador's Ministry of Finance has announced the publication of updated transfer pricing guidelines (DG-001/2018), which replace the prior guidelines issued in 2012. The guidelines cover: Application of the transfer pricing rules for transactions with related parties and parties located in jurisdictions with preferential tax regimes or low or no taxation (tax havens); Comparability analysis and adjustments; Price determination, including methods and acceptable ranges; Steps for the application of selected methods; Presentation of the transfer pricing report; Maintenance of documentation, information, and proof; Tax treatment of transactions with related parties and tax havens with respect to withholdings and non-deductible costs...