Bolivia's Tax Authority (SIN) issued Resolution No. 102600000016 on 27 May 2026, updating its official list of tax haven jurisdictions to 63 countries or regions, with application dates determined by the taxpayer's fiscal year-end and transitional provisions effective from 30 September 2026.
Bolivia’s Tax Authority (SIN) has issued Resolution No. 102600000016 on 27 May 2026, which updates the official list of countries or regions considered to have low or zero taxation (tax havens). This update is critical for taxpayers as it impacts tax returns, transfer pricing documentation, and other fiscal obligations.
The resolution serves as a legal instrument for the National Tax Service to monitor commercial and financial transactions involving these specific territories. By identifying these regions, the government aims to enforce stricter oversight regarding transfer pricing and corporate income tax obligations. The text also establishes specific compliance deadlines for taxpayers based on the end of their fiscal year to ensure a smooth transition to the new list.
Application and transition dates
The updated list is applied based on the taxpayer’s fiscal year-end:
- Tax years closing on or after 30 September 2026: Taxpayers must use the newly updated list attached to Resolution No. 102600000016.
- Tax years closing on or before 30 June 2026: Taxpayers must continue to follow the previous list established by Resolution No. 101900000002 from 15 February 2019.
Key changes to the list
The new list identifies 63 countries or regions. While the source provides the updated list rather than an explicit list of removals, a comparison confirms that several territories are no longer included, such as Panama, Barbados, the United Arab Emirates, and several British Crown Dependencies (like Guernsey and Jersey’s sub-territories).
Purpose and legal framework
In Bolivia, classifying a jurisdiction as a tax haven carries several tax consequences. Transactions with entities in such jurisdictions are treated as related-party dealings for transfer pricing purposes, requiring specific documentation and studies. The tax authority’s audit and penalty limitation period is also extended by two additional years where transactions involve these jurisdictions. A jurisdiction may be designated as a tax haven if it is listed as non-cooperative by the OECD or recognised as such by at least four South American countries.
Current list of 63 tax havens
Andorra, Angola, Anguilla, Antigua and Barbuda, Svalbard Archipelago, Aruba, Ascension, Bahamas, Bahrain, Belize, Bermuda, Bonaire, Saba, and St. Eustatius, Campione D’Italia, Cyprus, Djibouti, Dominica, Gibraltar, Guam, Guyana, Honduras, Hong Kong, Isle of Man, Cayman Islands, Christmas Island, Cook Islands, Cocos (Keeling) Islands, Marshall Islands, Norfolk Island, Queshm Island, Solomon Islands, St. Pierre and Miquelon, Turks and Caicos, British Virgin Islands, US Virgin Islands, Jersey, Kiribati, Labuan, Liberia, Liechtenstein, Macao, Maldives, Monaco, Nauru, Niue, Palau, Pitcairn, French Polynesia, Puerto Rico, Samoa, American Samoa, St. Vincent and the Grenadines, St. Helena, Seychelles, Sri Lanka, Sultanate of Oman, Swaziland, Tokelau, Tonga, Trinidad and Tobago, Tristan de Cunha, Tuvalu, Vanuatu, and Yemen.
