Reportedly, a Presidential Decree passed by the Legislative Assembly on 3 July 2013 will introduce transfer pricing (TP) rules applicable to business entities or individuals conducting transactions with related parties. The Presidential Decree still has to be published in the Official Gazette in order to enter into force. Currently, there is no transfer pricing legislation and the tax administration carries out transfer pricing adjustments between related parties under a principle of economic substance (realidad economica). Such adjustments, which are based on the use of the comparable uncontrolled price method, have been criticized by the private sector. The tax administration would...