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Major tax reform – 2010 (direct tax): Countries and territories with preferential tax regimes or tax havens 2010

26 April 2010

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Approved Changes

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El Salvador

As from 2010, taxpayers carrying out domestic and cross-border transactions with (i) related entities or (ii) individuals or entities constituted or located in tax havens or territories with preferential tax regimes (low or non-tax regimes) must determine the price or value of those transactions considering the market price agreed in similar transactions (price of goods transferred and/or services provided) by independent parties. The tax administration may adjust the price or value of the transactions described above if they are not carried out at arm's length. Additionally, as from 2010, any payments to residents of countries considered to be tax havens...