Transfer Pricing in El Salvador

Determine whether your company's transactions require transfer pricing analysis and documentation.

We carry out a preliminary assessment of related-party transactions and the tax obligations that may apply to the company.

The service may include:

• Identification of related-party transactions.
• Preliminary review of domestic and cross-border transactions.
• Identification of potentially applicable formal obligations.
• Initial assessment of available documentation.
• Identification of risks and compliance gaps.
• Recommendations on next steps.

For: companies conducting transactions with affiliated companies, shareholders, entities within the same business group or other related parties.

Document your related-party transactions through a technical analysis aimed at assessing their consistency with the arm's length principle.

The study is prepared considering the characteristics of the transactions, the functions performed, assets used, risks assumed and available information.

The service may include:

• Analysis of the transactions covered by the study.
• Functional characterization of the parties involved.
• Selection and application of the appropriate transfer pricing method.
• Comparability analysis.
• Search for and assessment of comparable information, where applicable.
• Economic analysis of the transactions.
• Preparation of the technical report.
• Identification of observations and recommendations.

The scope, methodology and deliverables will be defined according to the company's transactions, available information and applicable requirements.

Assess whether the conditions of transactions within your business group are consistent with those that independent parties would have agreed under comparable circumstances.

We can analyze transactions such as:

• Purchase and sale of goods.
• Provision of administrative, technical and professional services.
• Loans and financing between related companies.
• Royalties, licences and use of intellectual property.
• Leases of assets and real estate.
• Allocation of costs and expenses among group entities.
• Other transactions subject to the applicable transfer pricing rules.

Does your company already have a study? We review its documentation to identify aspects that require updating, expansion or clarification.

The service may include:

• Review of the study's scope.
• Assessment of the functional characterization.
• Review of the methodology applied.
• Analysis of supporting documentation.
• Identification of inconsistencies or missing information.
• Recommendations for updating or strengthening the report.

We support businesses in identifying and organizing documentation related to their tax obligations in this area.

The service may include:

• Review of applicable formal obligations.
• Guidance on required documentation.
• Support in preparing information related to affiliated-party transactions.
• Review of consistency between accounting records and transfer pricing documentation.
• Guidance on applicable forms or reports, according to the company's situation.
• Document preparation to address tax enquiries or requests.

The obligation to file returns, reports or studies depends on current provisions and each taxpayer's circumstances.

We help business groups understand the tax risks associated with transactions between affiliated entities in different jurisdictions.

The service may include:

• Identification of relevant cross-border transactions.
• Review of intragroup pricing policies.
• Analysis of shared-service charges.
• Documentary assessment of financing and royalties.
• Coordination of information among related entities.
• Identification of local documentation needs and coordination with advisers in other jurisdictions.

Advice on foreign legislation will be subject to the involvement of, and coordination with, qualified professionals in each jurisdiction.