Bolivia Transfer Pricing Documentation Requirements
Bolivia requires a transfer pricing study from corporate income tax payers whose related-party transactions exceed Bs 7,500,000, with an informative return, Form 601, filed annually. Documentation is produced within five days of a request, and penalties are expressed in inflation-indexed housing development units.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
TP documentation TP study
Required | Related-party transactions exceeding Bs 7,500,000 | 120 days after fiscal year-end | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 5 days. | ES | Yes (5,000 UFV for non-submission, indexed) |
Form 601 Informative return
Annual filing | Taxpayers with related-party transactions | 120 days after fiscal year-end | Submission deadline The documentation must be filed with the tax authority by the date shown. | ES | Yes |
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Scope of the documentation obligation
A corporate income tax payer whose related-party transactions, taken as the sum of all intercompany dealings regardless of type, exceed Bs 7,500,000 must prepare and submit a transfer pricing study. A taxpayer below that level need not submit a study but must keep documents proving its related-party transactions were at arm’s length, or that it made the necessary adjustment. The informative return, Form 601, is filed annually, and the study is produced within five days of a request. Documentation is presented in both physical and digital format.
Distinctive features of the Bolivian regime
Two features distinguish the Bolivian regime. The first is the penalty unit: sanctions are expressed in housing development units, an inflation-indexed unit of account, with non-submission of the study in physical form attracting 5,000 units, so the real value of the penalty tracks inflation rather than eroding over time. The second is the variable corporate tax year by sector, with closing dates of 31 December, 31 March, 30 June, or 30 September depending on whether the business is commercial, industrial, agribusiness, or mining, and the return due 120 days after that closing. Documentation is produced within five days of a request, among the shortest windows of any regime.
Benchmarking and comparables
Both local and foreign comparables are accepted. The rules do not specify the choice between single-year and multi-year testing, nor the frequency of a fresh search. The limitation period is eight years, extended to ten years where transactions involve low- or no-tax countries and regions, and transfer pricing audits may be performed within a two-year period.
Frequently asked questions
What must a Bolivian taxpayer below the threshold do?
A taxpayer with related-party transactions of Bs 7,500,000 or less need not submit a study but must keep documents proving its related-party transactions were at arm's length, or that it made the necessary adjustment.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.