Bolivia: Transfer pricing requirements

Transfer pricing provisions in Bolivia

A presidential decree (Supreme Decree N. 2227) includes transfer pricing requirements that generally are consistent with the rules under the OECD Transfer Pricing Guidelines and the transfer pricing regimes in other Latin America countries.

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In summary, the transfer pricing regulations in Bolivia generally concern intercompany transactions (both commercial and financial) between related parties for income tax purposes. In general, Bolivia’s transfer pricing rules address:

  • The definition of “related parties”
  • What may be considered to be appropriate comparability factors, interquartile ranges, and transfer pricing methods (in general, consistent with the OECD guidelines)
  • What six method may apply for commodity transactions (in general, consistent with the rules in Argentina)
  • The requirements for taxpayers to follow to comply with the arm’s length principle
  • Transfer pricing documentation rules that taxpayer will be required to follow and requirements for documentation to be presented to the tax authorities (guidelines establishing the timing as well as the details required in this documentation is pending future release by the authorities)
  • The establishment of a transfer pricing technical committee (one that would include customs officials)
  • The availability of a transfer pricing report also being made available and applicable for trade and customs purposes 


For more information, contact a tax professional with Ruizmier Jauregui S.R.L* in Bolivia:

Carola Jáuregui | | +(591 3) - 3434555  

Sergio Ruiz Mier | | +(591 2) - 2442626 


*Ruizmier Jauregui S.R.L is a firm in Bolivia that is independent from KPMG International and its member firms.

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