Under the rules, any taxpayer that forms part of an MNE group must inform the tax administration of the entity appointed to file the CbC report. The notification must include the designated filer’s commercial name, tax identification number, and address.
Multinational enterprise (MNE) groups operating in Honduras must submit their Country-by-Country (CbC) reporting notification by 31 December 2025, in line with Agreement SAR-653-2023, published in the Official Gazette on 19 March 2024.
Under the rules, any taxpayer that forms part of an MNE group must inform the tax administration of the entity appointed to file the CbC report. The notification must include the designated filer’s commercial name, tax identification number, and address.
Agreement SAR-653-2023 establishes the local framework for CbC reporting, which applies to MNE groups with consolidated revenue exceeding EUR 750 million (or HNL 19 billion). A CbC report must be filed in Honduras if:
- the ultimate parent entity is domiciled in Honduras and meets the revenue threshold;
- a Honduran entity has been appointed by the parent company to submit the report; or
- The MNE group files its report in a jurisdiction that does not have an information-exchange agreement with Honduras.
Exemptions apply where the group does not meet the revenue threshold or where the report is filed in a jurisdiction that has an exchange agreement with Honduras and no systematic reporting failures.
In all cases—whether or not a Honduran entity is required to file the CbC report—taxpayers must send a digital notification to the tax authority by the end of the ultimate parent entity’s fiscal year. The notification must state whether the local entity is the ultimate parent or a constituent entity, and, if applicable, identify the designated reporting entity.
Submission deadlines include:
- CbC report: within 12 months after the last day of the parent entity’s fiscal year.
- Notification: no later than the last day of the parent entity’s fiscal year.
Failure to submit or late submission of the notification is subject to penalties under Article 160 of the Tax Code, while late or missing CbC reports carry a fine of USD 10,000 as provided by the Transfer Pricing Regulation Law.
Honduras first introduced CbC reporting requirements in 2017 through Agreement SAR-007-2017, aligning with OECD BEPS Action 13 and the organisation’s transfer pricing guidelines.
