On March 21st, 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:

  1. 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.
  2. The presentation of a report with the Transfer Pricing transactions.
  3. The conservation of the documentation related to Transfer Pricing transactions.
  4. Tax withholdings in the Transfer Pricing transactions.
  5. Identification of nondeductible costs and expenses related to Transfer Pricing transaction to determine net income of tax payer. 
  6. The auditors' settlement in its fiscal report that the Transfer Pricing transactions are in compliance with the tax regulations.
  7. 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 supersedes the previous guidelines DG-001/2012 from March 2012.

You can read the text of the guideline by clicking here (only available in spanish)