author_orbitax
Orbitax

Share This Article

Panama Decree on Application of the Arm's Length Principle and Transfer Pricing Documentation Requirements Enters into Force

09 January 2017

|

Approved Changes

|

Panama

On 1 January 2017, Executive Decree No. 390 entered into force regarding Panama's transfer pricing regime. The decree confirms and clarifies certain aspects of the regime, and introduces additional information and documentation requirements. The main aspects of the decree include: Transactions should be analyzed individually according to the methods set in the tax code, although two or more transactions may be grouped if integrated economically or continuous and cannot be assessed separately; Multiple-year data may only be used for comparability analysis if it adds value to the analysis or improves reliability in relation to relevant economic cycles and the life...