Global

Details

  • Service: Tax, Global Transfer Pricing Services, Global Compliance Management Services
  • Type: Regulatory update
  • Date: 6/27/2012

Panama - Transfer pricing reports for calendar-year taxpayers due 30 June 

June 27:   Taxpayers in Panama are required to report transactions with foreign related parties to the Panamanian tax authorities (Dirección General de Ingresos—DGI).

For calendar-year taxpayers (i.e., those having a calendar year ending 31 December), the due date for filing the transfer pricing report on Form 930 (Informe de Precios de Transferencia) is 30 June.


In June 2012, a software application that allows taxpayers to file the transfer pricing reports electronically was launched on the DGI website.


Background

Ley 33 (June 2010) (Spanish) [PDF 1.39 MB] imposed certain requirements on taxpayers with respect to foreign related-party transactions:


  • A requirement to file an annual disclosure statement of operations with foreign related parties within six months of the end of the tax year
  • A requirement to maintain analysis and documentation adequate to support the implementation of the arm’s length principle with respect to transactions with related parties

Under Article 762-D of the tax law, taxpayers who are subject to the reporting requirement are those that conduct transactions with related parties that are tax residents of countries which have concluded income tax treaties for the avoidance of double taxation with Panama and that have an income tax system that measures revenue in relation to costs or deductions in determining taxable income.


Failure to file a transfer pricing report is subject to penalties, with the penalty amount based on whether a first-time or repeated failure.


Read a June 2012 report (Spanish) [PDF 226 KB] prepared by the KPMG member firm in Panama: Informe de Precios de Transferencia – Formulario 930




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