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 Guatemala
Tax Authority
Compliance with transfer pricing regulations is reviewed by the Superintendency of Tax Administration (SAT).
Companies with transactions between related parties abroad must have a Transfer Pricing Technical Study and submit the corresponding Annex along with the Annual Income Tax Return, as applicable.
Key Obligations
A lack of technical support may result in adjustments to the tax base, unpaid taxes, fines, interest, or increased exposure to tax audits.
Non-compliance Risks
For the immediately preceding fiscal year, the main compliance deadline in Guatemala is:
March 31: Filing of the Transfer Pricing Schedule along with the Annual Income Tax Return.
The Technical Study must be prepared and available upon request by the SAT.
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 typically form part of the analysis
In Guatemala, transfer pricing rules primarily apply to transactions between resident taxpayers and related parties located abroad. These transactions must be agreed upon in accordance with the arm’s-length principle, demonstrating that the prices, amounts, or margins used correspond to comparable market conditions.
Transfer pricing documentation allows taxpayers to substantiate the reasonableness of intercompany transactions, properly prepare the Transfer Pricing Schedule, and address requirements from the Superintendency of Tax Administration with greater certainty.
Compliance in Guatemala requires documenting transactions with related parties abroad
Selection of the applicable transfer pricing method.
Description of the intercompany 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 Guatemala
Find all the key steps, dates, and obligations your company must review to properly comply with Guatemalan regulations in a single document.
Before ensuring compliance in Guatemala, check to see if you have:
Clear identification of transactions with related parties.
Contracts, invoices, and supporting documentation.
A functional analysis of the entities involved.
Up-to-date financial information.
Benchmarking or comparability analysis, when applicable.
Consistency between intercompany policy and the group’s actual operations.
Technical study prepared in the event it is requested by the SAT.
Leaders in Transfer Pricing Advisory Services in Latin America
Our team can assist you in reviewing, preparing, or strengthening your transfer pricing documentation in Guatemala, 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 Guatemala 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 functions were 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 Guatemala are primarily set forth in the Tax Update Law, Decree 10-2012, and its implementing regulations, Government Agreement 213-2013. These provisions incorporate the Special Valuation Rules for Related Parties and establish documentation, analysis, and disclosure requirements for transactions between related parties.
These rules stipulate that intercompany transactions must be agreed upon in accordance with the arm’s-length principle, that supporting documentation must be retained, and that the relevant information must be disclosed when the taxpayer falls under the applicable circumstances.
Transfer Pricing Regulations in Guatemala
Guatemalan transfer pricing regulations were incorporated through Chapter VI of Title II of the Tax Update Law, Decree 10-2012. These provisions address valuation criteria, documentation requirements, analysis methods, and rules applicable to transactions between related parties.
The Regulations of the Tax Update Law, Government Agreement 213-2013, elaborate on aspects related to supporting documentation, the Technical Transfer Pricing Study, and the Annex on Transactions with Related Parties.
Applicable Legislation in Guatemala
Definition of a Related Party in Guatemala
In Guatemala, a person resident in the country and a person resident abroad are considered related parties when there is direct or indirect participation in the management, control, or capital of the other, or when the same person or group participates in the management, control, or capital of both.
Exclusive distributors or agents, permanent establishments, parent companies, and entities that are part of the same business group may also be considered related parties, in accordance with the provisions set forth in the applicable regulations.
The correct identification of related parties is essential for determining whether there is an obligation to document, analyze, and disclose transfer pricing information.
Supporting Documentation
Taxpayers engaging in transactions with related parties must prepare and maintain a Transfer Pricing Technical Study containing sufficient information and analysis to demonstrate that prices, consideration amounts, or profit margins were determined in accordance with the arm’s-length principle.
This documentation may include functional analysis, financial information, contracts, invoices, comparables, the selected method, and technical conclusions supporting the reasonableness of the transactions.
Transfer Pricing Disclosures
In Guatemala, taxpayers must file the Annual Income Tax Return and indicate whether they engaged in transactions with related parties abroad. Where applicable, they must submit the Related-Party Transactions Schedule along with said return.
The Transfer Pricing Technical Study is not automatically filed with the annual return, but it must be prepared and available for submission to the SAT upon written request.
Key Dates:
March 31: Annual Income Tax Return and Related-Party Transactions Schedule, when applicable.
Retention and Submission of the Technical Study
Documentation related to transfer pricing calculations must be retained for the applicable statute of limitations period. In Guatemala, the general statute of limitations is four years, with certain circumstances under which it may be extended in accordance with the Tax Code.
When the SAT requests the Transfer Pricing Technical Study, the taxpayer must submit it within the deadline granted by the tax authority.
Transfer Pricing Methods
Guatemalan 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 selection of the method must take into account the nature of the transaction, the availability of comparable information, the functions performed, the assets used, and the risks assumed by the parties involved.
Failure to comply with transfer pricing reporting and documentation obligations may result in fines, tax adjustments, interest, and increased exposure to audits by the tax authorities.
If the Tax Administration determines that transactions with related parties were not conducted in accordance with the arm’s-length principle, it may adjust the taxable income for income tax purposes and impose the corresponding penalties in accordance with the Tax Code.
Check your company’s compliance
in Guatemala
Schedule a consultation with our team to find out if your related-party transactions have the necessary technical support to ensure full compliance in Guatemala.
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