Taxation and Transfer Pricing in LATAM – Key Updates for February and March 2025

Brazil strengthens control over commodity transactions

Brazil enacted Law No. 14.596/2023 on June 14, 2023, requiring companies to register in detail their commodity transactions between related parties. Normative Instruction RFB No. 2246/2024, published on December 30, 2024, introduces significant changes in the registration and documentation of these operations.

Mexico: SAT intensifies transfer pricing audits

Mexico’s Tax Administration Service (SAT) has tightened its transfer pricing audits, with a particular focus on:

1. Cross-border transactions and corporate restructurings.
2. Valuation of intangibles and financing operations.
3. Recurring losses in key sectors (steel, food, automotive, pharmaceutical, technology, etc.).

Chile: Update of the tax schemes catalog and new transfer pricing regulations

Chile’s Tax Authority (SII) has updated its catalog of tax schemes, adding 92 new schemes subject to oversight, with a focus on corporate reorganizations and tax optimization strategies.
At the same time, Law 21.713, aligning with OECD standards, has introduced improvements to the transfer pricing regime.
These reforms aim to provide greater legal certainty, enhance transparency, and facilitate tax compliance.

Peru: Impact of new IRS guidelines on transfer pricing

On January 15, 2025, the U.S. IRS issued memorandum AM 2025-001, emphasizing the alignment of transfer pricing with the actual benefits derived from intangibles. While these guidelines apply to U.S. regulations, they could influence transfer pricing policies in Peru, affecting multinational companies with operations in both countries.

Guatemala: New tax obligations for companies regarding transfer pricing

In Guatemala, companies engaging in transactions with related parties must comply with specific transfer pricing tax obligations:

1. Submit the Sworn Declaration by March 31 of the following year, detailing the transactions carried out.
2. Maintain a Technical Transfer Pricing Study available for the Tax Administration.
   Failure to comply may result in fines of up to Q5,000 or 1% of gross income.

Costa Rica: New transfer pricing obligations and key deadlines

In February 2025, Costa Rica’s General Directorate of Taxation published a draft resolution establishing the obligation to submit the Annual Informative Transfer Pricing Declaration exclusively through the TRIBU-CR electronic platform.
The declaration for the 2024 fiscal period must be submitted six months after the resolution comes into effect.

Is your company ready to face these tax changes?

Tax authorities in Latin America are strengthening transfer pricing oversight and adapting to international standards. These changes require greater diligence in corporate tax management to minimize risks and optimize regulatory compliance. Therefore, it is crucial to:
✔ Ensure regulatory compliance: Make sure your transfer pricing studies meet the new regulations.
✔ Assess risks and opportunities: Evaluate the impact of ongoing audits and tax opportunities in each country.
✔ Anticipate changes: Stay informed and adjust your tax strategy to mitigate risks.

📩 At ALS Transfer Pricing, we have a specialized team in taxation and transfer pricing across Latin America. We are ready to help you assess and effectively manage these tax challenges. Contact us and let’s ensure tax compliance together.

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