Bolivia: local rules

Bolivia applies the arm's length principle through art. 45, 45 bis and 45 ter of Ley 843 (Texto Ordenado), changed and added by Ley 549 of 21 July 2014. Art. 45 says that in dealings between related parties the transaction value must be the one agreed between independent parties in comparable market deals. Art. 45 bis lets the tax authority check these deals and adjust them when the agreed value does not match economic reality. Decreto Supremo 2227 of 31 December 2014 is the regulation. It lists who is a related party (art. 2), requires related companies in Bolivia to keep their own separate books and deal at market prices (art. 3), sets the comparability factors (art. 5) and the value range (art. 6), and lists the methods (art. 7). The rules only apply to the Impuesto sobre las Utilidades de las Empresas (IUE). The tax authority sets the filing details in RND 10-0008-15 of 30 April 2015, with later changes.

There are only two transfer pricing filings. They depend on the total value of related party dealings in the fiscal year (RND 10-0008-15, art. 7). At Bs 15,000,000 or more, the company files the Formulario 601 (a sworn information return on related party deals) and the Estudio de Precios de Transferencia (EPT, the study). From Bs 7,500,000 up to less than Bs 15,000,000, it files only the Formulario 601. Below Bs 7,500,000 nothing is filed, but the company must keep the support that shows its prices were at market. The study must be in Spanish, in bolivianos, and signed by the legal representative or the NIT holder. It has five parts: index, executive summary, functional analysis, economic analysis and conclusions (art. 4). The Formulario 601 is filled in the Da Vinci program and sent through the Oficina Virtual. Since RND 102600000014 of 16 April 2026, the study is sent as a signed PDF through the SIAT together with the financial statements, and the paper copy is gone. Both filings are due in the same time as the IUE return (art. 9). Bolivia has no master file, no separate local file and no country by country report.

Six methods are allowed (Ley 843 art. 45 ter and DS 2227 art. 7): comparable uncontrolled price, resale price, cost plus, profit split, transactional net margin, and the quoted price method for goods traded on transparent international markets. The method that best fits the facts is used, and there is no ranking. If none of the six fits, another method that suits the economic reality may be used. Deals are compared on five factors: the goods or services, the functions and risks, the contract terms, the market and the business strategies (DS 2227 art. 5). The comparable data gives a value range between a lower limit (the minimum plus a quarter of the spread) and an upper limit (the minimum plus three quarters of the spread). A price inside the range is accepted. A price outside the range is adjusted to the middle of the range, which is the minimum plus half of the spread (DS 2227 art. 6 and 8, and RND 10-0008-15 art. 10). Fees for services from related parties are deductible only if the service was really provided and linked to the taxed activity (DS 2227 art. 9).

Failing to file the study or the Formulario 601 is a breach of a formal duty. Under art. 162 of the Código Tributario (Ley 2492) the fine runs from 50 to 5,000 Unidades de Fomento de la Vivienda (UFV). RND 10-0008-15 art. 12 sets the top fine of 5,000 UFV for not filing. It sets half of that top fine for filing late before any tax authority action, and also for filing with errors or missing data. Paying the fine does not cancel the duty to file. If the tax authority adjusts a price and the IUE was underpaid, the fine for omitted payment is 100% of the tax not paid (Ley 2492 art. 165), plus interest. The adjustment goes through an audit with a vista de cargo that states the new value, the comparison and the method (DS 2227 art. 8). Ley 1733 of 27 May 2026 (Alivio Tributario) set up a temporary relief program that can waive some older debts and fines, so check it before paying an old fine.

Bolivia has not enacted Pillar Two. No income inclusion rule, undertaxed profits rule or domestic minimum top-up tax was found in Ley 843, its regulations or any SIN rule, so there is no Pillar Two deadline. Bolivia does not appear in the OECD list of Inclusive Framework members. A Bolivian subsidiary of a large group may still be affected by the rules of the parent's country.

The IUE return is due 120 days after the end of the fiscal year (DS 24051 art. 39), whether or not an external audit report goes with it. Bolivia does not use one tax year for everyone. The fiscal year end depends on the sector: 31 March for industrial and oil companies, 30 June for rubber, brazil nut, agricultural, livestock and agro-industrial companies, 30 September for mining companies, and 31 December for banks, insurers, commercial and service companies and everyone not listed. Because of this, no single year end is set for the whole country. The 120 days land on 30 April for a 31 December year end (29 April in a leap year), 29 July for 31 March, 28 October for 30 June, and 28 January for 30 September. The financial statements and the study are sent digitally through the SIAT (Formulario 605) in the same time as the return. Under Código Tributario art. 4, a deadline set in days of more than ten days is counted in calendar days, and if the last day is not a working day for the tax authority it moves to the next working day. The SIN often grants one-off extensions. For 31 December 2025 year ends it moved the IUE return and payment to 4 May 2026, and the digital filing of the financial statements, study and Formulario 601 to 30 June 2026 (RND 102600000014, its fe de erratas, and RND 102600000017). For 31 March 2026 year ends it moved both to 31 August 2026 (RND 102600000027). These are one-off rules, not standing ones. The tool shows the 120 day date, and shows the extended dates only when extended due dates are switched on.