Bolivia’s National Tax Service has issued Resolution No. 102600000016, updating the list of jurisdictions considered to have low or no taxation and non-cooperative regimes, with implications for transfer pricing rules and an extended statute of limitations in certain cases.
Bolivia’s National Tax Service has published Resolución Normativa de Directorio (RND) Nº 102600000016 on 27 May 2026, updating its list of jurisdictions considered to have low or zero taxation for tax control and transfer pricing purposes.
The resolution, which entered into force upon its official publication on 29 May 2026, is based on provisions under Law Nº 843 and Supreme Decree Nº 2227 governing transfer pricing, as well as Law Nº 2492 relating to the statute of limitations for tax audits. It provides that transactions with residents of listed jurisdictions are treated as controlled for transfer pricing purposes, whether or not they involve related parties. It also extends the statute of limitations by two additional years for taxpayers carrying out operations with such jurisdictions.
The updated list comprises 63 jurisdictions identified either as non-cooperative by the OECD or as low-tax jurisdictions recognised by at least four South American countries. It includes, among others, Andorra, Cyprus, Gibraltar, Hong Kong, Jersey, Cayman Islands, Liechtenstein, Monaco, Seychelles, and the British Virgin Islands.
Compared with the 2019 list, Honduras has been added, while 21 jurisdictions have been removed, including Barbados, Brunei, Panama, Malta, Mauritius, the United Arab Emirates, and several Caribbean and European territories.
The resolution establishes transitional application rules. For fiscal years ending up to 30 June 2026, taxpayers must continue applying the 2019 list under RND Nº 101900000002. For fiscal years ending on or after 30 September 2026, the updated list under RND Nº 102600000016 will apply.
