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Bolivia Sets Out Transfer Pricing Documentation Requirements

On 30 April 2015, the Bolivian tax administration published a resolution setting out transfer pricing documentation requirements for related party transactions. The main requirements are summarized as follows.

Filing Requirements

The documentation filing requirements depend upon the annual value of transactions with related parties:

  • Taxpayers with annual transactions with related parties exceeding BOB 15 million must file a sworn informative statement and a full transfer pricing report;
  • Taxpayers with annual related party transactions exceeding BOB 7.5 million but not exceeding BOB 15 million must file a sworn information statement and a brief report of transactions with related parties;
  • Taxpayers with annual related party transactions not exceeding BOB 7.5 million are not required to file documentation, but must maintain documentation demonstrating their compliance with the arm's length principle

Transfer Pricing Report Requirements

A full transfer pricing report should include the following information:

  • A description of the taxpayer's industry and markets in which it operates;
  • A description of the organizational and corporate structure of the taxpayer's group;
  • Details of related parties, including the type of relationship and the transactions performed;
  • The business strategies and policies for determining pricing levels;
  • The transfer pricing method selected;
  • The transactions, agreements, or contracts concluded with related parties, including a description of the activities, assets used, and risks assumed by both parties;
  • The financial indicators used in determining the arm's length price, including profitability ratios, debt ratios, interest rates, and methods for calculating royalties for use of intangibles;
  • The amount of related party transactions, including outstanding balances; and
  • A comparability analysis, including a description of the comparable sources

Currency Requirements

Related party transactions should be compared with similar transactions denominated in Bolivian currency (boliviano, BOB). If the transaction is made in another currency, it must be converted to BOB using current exchange rates published by the Central Bank of Bolivia. In the event there is no direct exchange rate in Bolivia, the currency used should be converted to USD and then converted to BOB.

Language Requirements

Documentation should be in Spanish.

Effective Date

The documentation requirements are effective 1 May 2015.

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