Taxpayers conducting intercompany transactions must file an annual special transfer pricing return (Declaración Informativa de Operaciones entre Relacionados—DIOR) as well as a transfer pricing study that includes an independent analysis of the reported intercompany transaction(s).
The free trade zone rules do not expressly providing an exception to these reporting requirements. However, the tax administration (Dirección General de Impuestos Internos—DGII) is allowing entities located in free trade zones to apply for a ruling request for a compliance waiver. A waiver would allow entities operating in free trade zones to be exempt from the filing of the DIOR and of the transfer pricing study.
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