On 1 July 2020, the Government published Resolution No. NAC-DGERCGC20-00000046 of 1 July 2020, which amends the calculation of profit level indicators. According to amendments, it is provided that taxpayers must use the last financial information from independent third parties that is available prior to filing the tax declaration for the year analyzed.
On the other hand, previously Resolution No. NAC-DGERCGC16-00000531 of 2016 made amendments regarding export transactions, which introduced rules to prevent transfer pricing abuse in such type of transactions. Under the Resolution, methods are provided of how to determine the transfer prices for banana exports involving related parties in the EU, Russia, and other countries.
