Meet your tax obligations in related-party transactions with technical documentation, defensible analysis, and specialized support.
What Your Company Needs to Keep in Mind in Honduras
Tax Authority
Transfer pricing compliance is reviewed by the Revenue Administration Service (SAR).
Companies with transactions between related parties may be subject to the Annual Informative Affidavit on Transfer Pricing, the Transfer Pricing Study, and, where applicable, the Country-by-Country Report.
Key Obligations
A lack of technical documentation may result in tax adjustments, disallowance of intercompany costs or expenses, formal fines, or increased exposure to audits by the tax authority.
Non-compliance Risks
For the immediately preceding fiscal year, the main compliance deadline in Honduras is:
April 30: Filing of the Annual Informative Affidavit on Transfer Pricing.
The Transfer Pricing Study must be ready in case it is requested by the SAR.
Functional analysis of functions, assets, and risks.
Benchmarking or comparability analysis, where applicable.
Identification of the related parties involved.
Financial information on the taxpayer and the transactions analyzed.
Elements that are typically part of the analysis
In Honduras, commercial and financial transactions between related parties must be valued in accordance with the arm’s-length principle. This means that the prices, amounts, or margins used must be comparable to those that independent parties would have agreed upon under similar conditions.
Transfer pricing documentation allows you to substantiate the reasonableness of intercompany transactions, properly prepare the Annual Informative Tax Return, and have technical support in the event of potential requests from the Revenue Administration Service.
Compliance in Honduras requires correctly valuing and documenting related-party transactions
Selection of the applicable transfer pricing method.
Description of the commercial or financial transactions carried out.
Review of contracts, invoices, and supporting documentation.
Conclusion regarding compliance with the arm’s-length principle.
Download the Transfer Pricing Compliance Roadmap for Honduras
Find all the key steps, dates, and obligations your company must review to properly comply with Honduran regulations in a single document.
Before ensuring compliance in Honduras, check that you have:
Clear identification of transactions with related parties.
A review of the applicable threshold for filing the informational return.
Contracts, invoices, and supporting documentation.
A functional analysis of the entities involved.
Up-to-date and segmented financial information.
Benchmarking or comparability analysis, when applicable.
Consistency between the intercompany policy and the group’s actual operations.
Transfer pricing study prepared upon request by the SAR.
Leaders in Transfer Pricing Advisory Services in Latin America
Our team can assist you in reviewing, preparing, or strengthening your transfer pricing documentation in Honduras, taking into account local regulations and your business group’s actual operations.
Local Documentation
Benchmarking
Review of Intercompany Policies
Support during audits or in response to regulatory requests
We assist business groups with operations in various countries across the region, combining local compliance, a regional perspective, and specialized technical support.
+1,200
Annual Studies
Why Choose Grupo Consultor EFE® for Your Transfer Pricing Compliance
Experience in documenting and analyzing intercompany transactions.
+600
clients
Support for local businesses, business groups, and companies with international operations.
Support in Honduras and other Latin American countries for companies with multinational structures.
Integrated Vision
Local + Regional
Technical + Strategic
Differentiated
Documentation prepared to comply with, support, and defend the transaction during audits.
At Grupo Consultor EFE®, we understand that transfer pricing compliance is not merely a tax obligation. It can also serve as a tool to strengthen decision-making, assess the efficiency of intercompany transactions, and anticipate risks in an increasingly regulated environment.
The support they provide throughout the entire process is consistent and highly responsive. Their commitment to completing each stage is evident, as is the high level of professionalism with which they approach every project. Their approach builds trust from the start, and the results clearly reflect their serious and responsible approach. The way they engage and deliver on their promises is truly exemplary.
Companies That Have Placed Their Trust in Us
Real results from business groups that demonstrate their compliance with our technical support.
Rosa Delia Silva Pineda
Flextronics
"
Working with your team has been a positive experience from start to finish. From our very first contact, they demonstrated a high level of professionalism, attention to detail, and clarity in communication. The results we achieved were fully in line with our expectations, which confirms the quality and effectiveness of your services.
Argentina Hidalgo
EMASAL Group
"
It was my first time working on transfer pricing; the support and follow-up were excellent and appropriate. At our corporate office in San Diego, we were asked to conduct a transfer pricing study; previously, our company’s accounting was handled by an external firm, and they were the ones who recommended Grupo Consultor EFE® to us.
Pablo Rafael Xep
CPS
"
Transfer pricing regulations in Honduras are primarily set forth in the Transfer Pricing Regulation Act, contained in Decree No. 232-2011, and in its implementing regulations, issued by Agreement No. 027-2015.
These provisions establish that commercial and financial transactions between related parties must be valued in accordance with the arm’s-length principle, supported by documentation, and the corresponding information must be submitted when the taxpayer falls under the applicable circumstances.
Transfer Pricing Regulations in Honduras
The Transfer Pricing Regulation Act establishes the rules applicable to the valuation of transactions between related parties in Honduras. This legislation was supplemented by the Transfer Pricing Regulations, which detail documentation requirements, the submission of studies, analysis methods, and comparability criteria.
The Tax Code also introduced relevant provisions for compliance with transfer pricing regulations, including general reporting obligations, record retention periods, and the tax authority’s audit powers.
Applicable Legislation in Honduras
Definition of a Related Party in Honduras
In Honduras, two or more persons are considered related parties when there is direct or indirect participation in the management, control, or capital of another company, or when the same individuals or legal entities participate directly or indirectly in the management, control, or capital of both companies.
Related-party relationships may also arise in transactions with parties located in jurisdictions considered tax havens, agents, distributors, or exclusive dealers; permanent establishments; companies that are part of the same decision-making unit; or entities that share directors or managers.
The correct identification of related parties is essential for determining whether there is an obligation to document, analyze, and disclose transfer pricing information.
Annual Informative Affidavit on Transfer Pricing
Income tax taxpayers who engage in commercial or financial transactions with related parties must file an Annual Informative Affidavit on Transfer Pricing with the Tax Administration.
This return must include information for the prior tax year and applies, among other cases, to medium- and large-sized taxpayers with related-party transactions, taxpayers with related-party transactions under special tax regimes, transactions with parties located in tax havens, and small taxpayers who exceed the applicable threshold.
Reference Date:
April 30: Annual Informative Affidavit on Transfer Pricing for taxpayers with a calendar fiscal year.
Supporting Documentation
Taxpayers subject to the Transfer Pricing Regulation Act must have a Transfer Pricing Study that demonstrates that their transactions were determined in accordance with the arm’s-length principle.
This documentation may include a description of activities, functions performed, risks assumed, assets used, identification of related parties, valuation methods used, details of comparable transactions, and any additional information necessary to justify intercompany transactions.
Retention and Submission of the Transfer Pricing Study
Documentation and information related to the calculation of transfer prices must be retained for the applicable statute of limitations period. In Honduras, the Tax Code establishes a broad period during which the tax authority may review, verify, monitor, determine, audit, and assess taxes.
The Transfer Pricing Study must be prepared for submission to the Tax Administration upon request within the timeframe set by the authority.
Language of the Documentation
Documentation submitted to the tax authority must be prepared in Spanish.
Small taxpayers who conduct commercial or financial transactions with related parties within the same tax period for a cumulative amount exceeding one million U.S. dollars, or its equivalent in lempiras, are required to file the Transfer Pricing Informative Return and maintain the corresponding study.
Honduran regulations provide for various methods to assess whether transactions between related parties are conducted in accordance with the arm’s-length principle.
Accepted Methods:
The regulations also allow for the use of a different method when the taxpayer demonstrates that none of the prescribed methods is reasonably applicable to analyze a transaction between related parties.
Honduran law allows the use of internal or external comparables to determine the range of effective arm’s-length pricing in the evaluation of transactions carried out by a company.
When two or more comparable transactions exist, a range of prices, consideration amounts, or profit margins may be determined, especially when market analysis does not yield an exact amount but rather a reasonable approximation.
Honduras has incorporated elements aligned with international standards regarding transfer pricing and tax transparency. Among these are the Master File and the Country-by-Country Report, which may be requested or required in accordance with the criteria established by the tax authority.
Under recent provisions, the Country-by-Country Report applies to taxpayers that are part of multinational groups exceeding the established consolidated revenue thresholds.
Failure to comply with transfer pricing reporting and documentation obligations may result in fines, tax adjustments, disallowance of costs or expenses, interest charges, and increased exposure to audits by the tax authority.
The Tax Administration may make adjustments to revenue, costs, deductible expenses, or reported profit or loss when it determines that transactions between related parties do not comply with the arm’s-length principle. Additionally, the submission of incomplete, inaccurate, or false information may increase the risk of penalties.
Check your company’s compliance
in Honduras
Schedule a consultation with our team to find out if your related-party transactions have the necessary technical support to ensure proper compliance in Honduras.
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