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TP regulation round-up: Iceland and Guatemala


Iceland has recently enacted transfer pricing legislation but Guatemala has announced its laws will be delayed until 2015.

Iceland’s transfer pricing legislation will follow OECD guidelines and is effective from January 1 2014.

Previously, Icelandic officials only had access to a general anti-avoidance principle which provided for adjustments for transactions when the authorities demonstrated that the basis for the price, as reported, was abnormal.

Guatemala has postponed the transfer pricing legislation that was enacted in February 2012. While the rules were originally scheduled for an effective date of January 2013, it seems neither taxpayers nor the authorities are prepared for them.

Article 27 of Decree No 19/2013 has delayed the legislation until January 1 2015 but the authorities have a right to request transfer pricing documentation through the course of 2015.

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