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Taxation and Transfer Pricing in LATAM – Key Updates from February and March 2025
LATAM tax authorities are tightening transfer pricing controls with new obligations, audits, and alignment with OECD standards. At ALS Transfer Pricing, we offer expert advisory services to help companies anticipate risks, ensure regulatory compliance, and adapt their tax strategies across the region.
Brazil: Strengthened Oversight of Commodity Transactions
Brazil enacted Law No. 14.596/2023 on June 14, 2023, requiring companies to register their related-party commodity transactions in detail. Instruction RFB No. 2246/2024, published on December 30, 2024, introduces major changes to the reporting and documentation of these operations.
Mexico: SAT Intensifies Transfer Pricing Audits
Mexico’s Tax Administration Service (SAT) has tightened transfer pricing audits, with particular focus on:
Cross-border transactions and corporate restructurings.
Valuation of intangibles and financing operations.
Recurring losses in key sectors (steel, food, automotive, pharmaceutical, tech, etc.).
Chile: Updated Tax Scheme Catalog and New Transfer Pricing Rules
Chile’s Tax Authority (SII) has updated its catalog of reportable tax schemes, adding 92 new schemes subject to scrutiny—particularly those related to corporate reorganizations and tax optimization strategies.
In parallel, Law 21.713, aligning with OECD standards, introduces reforms to the transfer pricing regime aimed at enhancing legal certainty, transparency, and compliance.
Peru: Impact of New IRS Guidelines on Transfer Pricing
On January 15, 2025, the U.S. IRS issued memorandum AM 2025-001, highlighting the need to align transfer pricing with the actual economic benefits derived from intangibles. Although these guidelines apply to U.S. law, they could influence transfer pricing policies in Peru, particularly for multinational companies operating in both jurisdictions.
Guatemala: New Transfer Pricing Obligations for Companies
In Guatemala, companies engaged in related-party transactions must comply with specific transfer pricing obligations:
Submit the sworn declaration by March 31 of the following year, detailing the transactions performed.
Maintain a Technical Transfer Pricing Study, available to the Tax Administration upon request.
Non-compliance may lead to fines of up to Q5,000 or 1% of gross revenues.
Costa Rica: New Transfer Pricing Requirements and Key Deadlines
In February 2025, Costa Rica’s General Directorate of Taxation published a draft resolution establishing that the Annual Transfer Pricing Informative Return must be submitted exclusively through the TRIBU-CR electronic platform.
The return for the 2024 fiscal year must be filed six months after the resolution comes into effect.
Is Your Company Ready for These Tax Changes?
Tax authorities across Latin America are stepping up transfer pricing enforcement and aligning with international standards. These developments require greater diligence in managing tax compliance to minimize risk and optimize legal adherence. It is therefore essential to:
✔ Ensure regulatory compliance: Make sure your transfer pricing studies meet the latest legal requirements.
✔ Assess risks and opportunities: Analyze the impact of ongoing audits and identify tax opportunities in each country.
✔ Stay ahead of changes: Stay informed and adjust your tax strategy to mitigate emerging risks.
At ALS Transfer Pricing, we have a team specialized in tax and transfer pricing across Latin America. We are ready to help you evaluate and manage these tax challenges effectively. Contact us and let’s ensure compliance together.
