The General Revenue Directorate (DGI), through Resolution No. 201-5949 dated June 26, 2023, extends the deadline for filing the "Transfer Pricing Report", also known as "Form 930″ for the period 2022 until July 14 of the current year.
This represents an opportunity for those taxpayers that enter into operations with other entities of the same business group or with which they have some kind of relationship, to comply with this obligation and avoid penalties for omission.
The obligation of such report is established in Article 762-I of the Tax Code of the Republic of Panama and its content is provided in Resolution No. 201-3338 of June 17, 2020. Failure to file this report entails a fine of 1% of the total amount of the operations with related parties and can reach up to one million dollars.
In this regard, during the last year, there has been an increase in the application of fines by the DGI, especially for those local transactions in which one of the parties is located in Free Zones, Free Trade Zones, Special Economic Areas and Special Regimes and which were not subject to the obligations until 2019. In addition, the DGI is applying fines for failures in the content of the transfer pricing studies with respect to the provisions of Article 10 of Executive Decree 390 of October 24, 2016.