On 21 March 2018, the General Directorate of Internal Taxes of the Ministry of Finance issued the Transfer Pricing Orientation Guide (DG-001/2018).

These guideline is intended to help taxpayers to comply with the following legal obligations:

  • The determination of transfer prices in transactions carried out with (i) related parties or (ii) with persons domiciled, constituted or located in countries, states or territories with a policy of low or no taxation.
  • The presentation of a report with the Transfer Pricing transactions.
  • The conservation of the documentation related to Transfer Pricing transactions.
  • Tax withholdings in the Transfer Pricing transactions.
  • Identification of nondeductible costs and expenses related to Transfer Pricing transaction to determine net income of tax payer.
  • The auditors’ settlement in its fiscal report that the Transfer Pricing transactions are in compliance with the tax regulations.
  • Examples relating to points 1-6, mentioned above.

The Guideline was developed in response to the amendment of article 62-A of the Salvadoran Tax Code (1) effective since 2014 and replaces the previous guidelines DG-001/2012 from March 2012.