According to the Regulatory Decree 3030 of December 2013, transactions over 32,000 UVT by type of transaction are subject to transfer pricing analysis only if the total amount of the transactions exceeds 61,000 TVU. In the case of transactions with persons or entities resident or domiciled in low tax jurisdictions the normal thresholds do not apply and transfer pricing documentation must be prepared if the amount of the transactions exceeds 10,000 UVT. Where the taxpayer corrects errors or inconsistencies in the return before the tax authority issues a penalty the penalty is reduced to 50% of the amount determined in the official assessment. The TP regulations permit an APA to be concluded for five years including a rollback of one year.
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