Honduras Transfer Pricing Documentation Requirements
Honduras requires transfer pricing documentation, with a USD 1 million threshold for small taxpayers but no threshold for large and medium taxpayers, whose status the tax authority sets. An annual information return is filed, and penalties are geared to any adjustment.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
TP documentation Required | Large and medium taxpayers (no threshold); small taxpayers above USD 1m of intercompany transactions | By tax return filing date | 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 10 days. | ES | Yes (USD 20,000, or 15% to 30% of the adjustment) |
TP information return Annual filing | Taxpayers with related-party transactions | Between 1 January and 30 April (December year-end) | Submission deadline The documentation must be filed with the tax authority by the date shown. | ES | Yes |
Calculate your exact Honduras deadline
Enter your entity’s fiscal year-end to return your exact Honduras preparation or filing date. Available without registration.
Scope of the documentation obligation
For small taxpayers, the documentation requirement applies where intercompany transactions exceed USD 1 million. For large and medium taxpayers there is no threshold, so any related-party dealings bring them into scope. The categories of large and medium taxpayer are set by the tax authority by reference to the taxes paid, with the authority issuing a list of each taxpayer’s category. Documentation is produced within ten days of a request, and an annual information return is filed following the fiscal year-end.
Distinctive features of the Honduran regime
Two features distinguish the Honduran regime. The first is the taxpayer-category gating, under which the threshold applies only to small taxpayers while large and medium taxpayers are caught regardless of transaction value, with the category determined administratively by the tax authority rather than by a statutory turnover line. The second is the adjustment-geared penalty: where the tax authority makes an adjustment, the fine is USD 20,000 or 15 to 30 percent calculated on the amount of the adjustment, so the consequence scales with the size of the correction. There is no published safe harbour.
Benchmarking and comparables
There are no benchmarking requirements specifically directing local or regional comparables, and given the limited local financial information, international comparables are accepted. Multi-year testing of the comparables, up to five years, is acceptable, although in practice three years are used. A fresh benchmarking search is conducted every year, with the report and return prepared annually and the tax authority expecting the most recent comparable information. The limitation period is five years, capable of extension with the filing of an amended return.
Frequently asked questions
Does the Honduran threshold apply to all taxpayers?
No. The USD 1 million threshold applies only to small taxpayers. Large and medium taxpayers, whose category the tax authority sets by reference to taxes paid, are caught regardless of the transaction value.
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.