Venezuela Transfer Pricing Documentation Requirements
Venezuela requires transfer pricing documentation from all companies with related-party transactions, regardless of the amount, produced within three days of a request. An informative return, Form PT-99, is filed within six months of year-end, and a failure to keep documentation can close the office for ten days.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
TP documentation Required | All companies with related-party transactions, regardless of amount | 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 3 days. | ES | Yes (10-day office closure plus a substantial indexed fine) |
Form PT-99 Informative return
Annual filing | Controlled parties with related-party transactions | Within 6 months of 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
Transfer pricing documentation is required of all companies that record transactions with related parties, regardless of the amount of those transactions. The documentation is produced within three days of a request, among the shortest windows of any regime. An informative return, Form PT-99, available on the tax authority’s website, must be filed within the six months immediately following the close of each tax year. There is no Country-by-Country reporting obligation in the regime as captured.
Distinctive features of the Venezuelan regime
Two features distinguish the Venezuelan regime. The first is the severity of the documentation penalty: a failure to maintain or preserve the documentation supporting the calculation of transfer prices is sanctioned with closure of the office or permanent establishment for ten continuous days, alongside a substantial fine indexed to the highest-value official exchange rate published by the central bank, so the consequence combines an operational shutdown with an inflation-resistant monetary penalty. The second is the very short three-day production window, which makes genuinely contemporaneous documentation essential. The informative return, Form PT-99, does not itself give rise to any payment.
Benchmarking and comparables
Regional comparables are accepted, although in practice the tax administration prefers comparables located in the United States and Canada. Both single-year and multi-year analysis are recognised, and data from previous years may be used to reduce the effect of macroeconomic variables, with the administration preferring the use of multiple years while comparing against a single year of the tested party. A roll-forward with an update of the financial information of prior comparables is usually used. The limitation period is six years from the date of filing the return, extended to ten years where the taxpayer fails to file any required return.
Frequently asked questions
How quickly must Venezuelan documentation be produced?
Within three days of a request, among the shortest windows of any regime, which makes genuinely contemporaneous documentation essential.
What penalty applies for failing to keep documentation in Venezuela?
Closure of the office or permanent establishment for ten continuous days, alongside a substantial fine indexed to the highest-value official exchange rate published by the central bank.
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.