Grant Thornton is a global network of 76,000 people in member firms in 156 markets, with one common goal — to help you realise your ambitions. Our member...
Whether you’re growing in one market or many, looking to operate more effectively, managing risk and regulation, or realising stakeholder value, our firms can help.
In a world that wants more options for high quality services, we differentiate in the market to grow sustainably in today’s rapidly changing environment.
Grant Thornton International Ltd acts as the coordinating entity for member firms in the network with a focus on areas such as strategy, risk, quality monitoring and brand.
The global leadership team (GLT), chaired by the GTIL CEO is a full-time management group dedicated to leading the network in the successful execution of the...
The relationship between a company and its auditor has changed. Organisations must understand and manage risk and seek an appropriate balance between risk and opportunities.
At Grant Thornton, we have a wealth of knowledge in forensic services and can support you with issues such as dispute resolution, fraud and insurance claims.
We work with entrepreneurial businesses in the mid-market to help them assess the true commercial potential of their planned acquisition and understand how the purchase might serve their longer-term strategic goals.
We can support you throughout the transaction process – helping achieve the best possible outcome at the point of the transaction and in the longer term.
We can assist you with a variety of sustainability advice depending on your needs, ranging from initial strategy development, reporting and compliance support, through to carbon measurement and management.
Our services can strengthen your business and stakeholders' confidence. You'll receive professionally verified results and insights that help you grow.
Our global assurance technology platform provides the ability to conduct client acceptance, consultations and all assurance and other attestation engagements.
Our sustainability assurance services are based on our global network of specialists, helping you make more efficient decisions for the good of your organisation.
Through our global organisation of member firms, we support both companies and individuals, providing insightful solutions to minimise the tax burden for both parties.
Using our finely tuned local knowledge, teams from our global organisation of member firms help you understand and comply with often complex and time-consuming regulations.
The laws surrounding transfer pricing are becoming ever more complex, as tax affairs of multinational companies are facing scrutiny from media, regulators and the public
Through our sustainability tax advisory services, we can advise how environmental taxes, incentives, and obligations can impact your progress, requiring alignment with governmental and legislative pressures.
We offer an extensive range of services to automotive sector stakeholders from supply chain through to distribution, retail and usership. With a variety of...
History has something important to tell us about the difficulties of steering a business to long-term success – through seismic shifts in technology, consumer demands and product development. With that in mind it’s unsurprising that over half the world’s largest companies in the early 1900s had shut their doors by the late 1990s. Some, however, have endured.
Following world events such as the COVID-19 pandemic, Brexit, and changes to regulation and digitalisation, insurers must be alert to the challenges ahead.
We help businesses navigate today’s changing private equity landscape, ensuring that you can respond to ever-changing regulations and investor demands.
When the global COVID-19 pandemic stormed across the globe in early 2020, the private equity sector was hit hard but deals are coming back to the market.
Nervous about partnering with Private Equity? We explore some of the common myths we come across when speaking to mid-market businesses about PE investment.
Jessica Patel, Tax Partner at Grant Thornton UK speaks with tax partners and directors across the network to share their insights on the real estate market and some of the challenges.
Jessica Patel, Tax Partner at Grant Thornton UK speaks with tax partners and directors across the network to share their insights on the real estate market and some of the challenges.
The past two years saw the retail industry experience significant disruption, however there will still be opportunities to effectively reposition for future...
Businesses are seeing rising challenges, and finance heads are dealing with a range of new measures. To say the next 12 months are critical for businesses is an understatement.
In this article, we’ve summarised key elements of the global tax reform proposals, their potential impact on technology industry and advice from our digital tax specialists on what technology companies can do to prepare.
Our research revealed five key trends that resonated with Technology, Media and Telecoms (TMT) industry leaders around the world. We asked a panel of our experts from UK, US, India Ireland and Germany, to give us their reaction to the findings.
Our research revealed five key trends that resonated with Technology, Media and Telecoms (TMT) industry leaders around the world. We asked a panel of our experts from UK, US, India Ireland and Germany, to give us their reaction to the findings.
Technology companies must adopt a new approach to digital risk: those that successfully develop a reputation for digital trust by demonstrating an unwavering commitment to cyber security and data privacy will be able to carve out a competitive advantage.
Figures suggest the mobile sector is maturing. While data usage continues to soar, mobile revenues are expected to flatten out over the next few years.
The COVID-19 pandemic caused unprecedented levels of disruption to the global travel industry. As this evolves, it is unclear what recovery looks like.
Optimism among global mid-market business leaders rose to 67% in the first half of this year and they are markedly more optimistic about their prospects with global optimism having increased by 8%.
For 21 years, the Women in Business report has tracked the proportion of women in senior roles in the mid-market. Progress has been made but with gender equity over 25 years away, that isn’t soon enough.
Mid-market firms are scaling sustainability for growth, not just compliance. Grant Thornton’s International Business Report (IBR) 2025 report reveals how sustainability investments are driving profitability, resilience and global expansion — despite regulatory shifts and political uncertainty.
Instability has come to define the global business landscape and the ability for mid-market firms to thrive through disruption is becoming a key differentiator.
A shifting global trade landscape is contributing to rising uncertainty, but could it also unlock new opportunites for adaptable mid-market businesses while larger companies opt to wait and see?
Women holding the CFO role is nearing parity – reshaping finance leadership and potentially helping increase female representation across all senior roles.
With seismic shifts in the global landscape, leaders must take deliberate action to propel their businesses into a more inclusive future, foster innovation,...
Women holding the CFO role is nearing parity – reshaping finance leadership and potentially helping increase female representation across all senior roles.
We saw an increase in the percentage of senior management roles held by women, on a global level, but there are some significant regional and country variations.
Mid-market firms are scaling sustainability for growth, not just compliance. Grant Thornton’s International Business Report (IBR) 2025 report reveals how sustainability investments are driving profitability, resilience and global expansion — despite regulatory shifts and political uncertainty.
The world needs a sustainable mid-market. It’s vital to economies, societies and the
planet. Businesses, governments, and other stakeholders must work collaboratively to make
sure this vital part of the world economy succeeds.
As organisations in the private sector make commitments and plans to reach net zero, there's a growing need for stakeholders to be able to assess the credibility of their transition plans.
Instability has come to define the global business landscape and the ability for mid-market firms to thrive through disruption is becoming a key differentiator.
A shifting global trade landscape is contributing to rising uncertainty, but could it also unlock new opportunites for adaptable mid-market businesses while larger companies opt to wait and see?
Across the globe, companies’ tax affairs are facing increasing scrutiny from regulators, communities and clients. Read our latest insights ranging from BEPS to...
Growing businesses that send their greatest assets – their people – overseas to work can face certain tax burdens, our global guide highlights the common tax rates and issues.
Helping you easily find everything you need to know about the rules and regulations regarding transfer pricing and Country by Country reporting for every country you do business with.
Global transfer pricing guide
Transfer pricing - EL Salvador
01 Jan 20255 min read
This publication provides a high-level overview of EL Salvador's transfer pricing rules and outlines who to contact for expert guidance in this area.
Contents
Introduction to transfer pricing in El Salvador
The transfer pricing (TP) legislation were introduced to the Salvadoran Tax Code since November 2009, effective as of 2010 fiscal year, in articles 62-A, 124-A, 135 literal f), 147 literal e), 199-A, 199-B, 199-C, 199-D and 244 literal I).
TP rules in El Salvador are mainly based in the OCDE Guidelines, however there are other specific domestic considerations that taxpayers needs to addressed, such as the definition of related party which include transactions conducted with entities located in preferential tax regimes and domestic transactions, local methods, among others.
The General Directorate of Internal Taxes (DGII) issued in 2018, the “Transfer Pricing Guide” aiming to facilitate the transfer pricing determination, as well as to address the relevant regulations around transactions between related parties. This document is based in the OECD Guidelines and local regulations.
Taxpayers must comply whit documentation requirements such as the transfer pricing report and the informative TP return.
The DGII annually issues a guide to facilitate the recognition of preferential tax regimes, listing several countries, states or territories that are considered by the Tax Administration as having low, no taxation or "tax heaven". Transfer pricing rules also applies to transactions conducted with a subject located or stablished in any of these territories.
The Salvadoran Transfer pricing rules are not completely aligned to the OECD Guidelines. Although OECD Guidelines where mentioned previously in the reform of article 62-A of July 2014, in May of 2018 the Constitutional Hall of El Salvador’s Supreme Court of justice issued a judiciary resolution leaving without effect that reform, which includes among others, the reference to the OECD Guidelines.
In March 2018, the Tax Authority issued the Transfer Pricing Guide, which is a general orientation for taxpayers required to comply with the TP rules, replacing the 2012 version. This guide includes the OECD methods for transfer pricing analysis, comparability analysis process and recommendations for preparing the TP documentation.
The OECD Methods are generally acceptable, preferably in a transaction by transaction basis, following the most appropriate method principles.
There is a local method used by the Tax Authority called the "Market Price" which is similar to the CUP method but with much more restriction in the number and type of comparable transactions. This method does not accept a range of comparable values and is generally applied by the tax authorities in the cases that the taxpayer fails to prepare the TP supporting documentation. For taxpayers, this method is inapplicable in most cases.
Transfer pricing documentation
According to article 147, literal C) of the Tax Code, it is mandatory for taxpayers to document the transactions conducted with related parties or subjects located in preferential tax regimes (transfer pricing report) and the pricing analysis. In case of a transfer pricing audit the documentation must be available for the Tax Administration. Any documentation must be prepared in Spanish and be keep for a period of 10 years.
The transfer pricing report must be prepared regardless of the transactions amount in the year.
The documentation must also be available for the External Tax Auditor prior to May 31st (in case the company appoints a tax auditor).
When transactions conducted with related parties in a fiscal year exceed USD 571K, taxpayer must prepare the TP informative return prior March 31st (for companies whose fiscal year ends in December).
The Transfer Pricing Guide of the Tax Authority refers to the supporting TP documentation that should include: background to the group and the company, the group legal and operative structure, an outline of the key intercompany transactions under analysis, an analysis of the key functions, assets and risks of the company, an industry analysis and an economic analysis including the comparables supporting evidence.
TP documentation must be prepared in Spanish and be kept by the taxpayer for a period of 10 years.
To the date, El Salvador has not incorporated into the TP legislation the documentation scheme proposed by the OECD in the framework of BEPS. And although the Master and Local file structure is best and standardized practice, there are local elements of the transfer pricing regulation that would be left out and could end in non-compliance with the TP rules.
The scope of TP rules applies for domestic transactions, transactions carried out with any subject that is located in preferential regimes, any subject with an exclusive distribution contract and a foreign supplier that represents more than 50% of total purchases. There is also a local method that should be analyzed, if applicable, or be discarded.
Intercompany services or royalty payments with lack of documentations, benefit test and materialization.
Sale of tangible goods at unit value below cost (even commodities).
Business restructurings without taking into consideration an anticipated TP analysis.
Persistent losses.
Payments or transactions through low tax jurisdictions.
Penalties in relation to transfer pricing informative return are derived from failure in submitting the form, submitting it out of the legal term (March 31st) and/or referring it without specifications contained in the Tax Code. In any of these cases the penalty will be of 0.5% over the equity or capital stock of balance sheet.
Daily interest may also apply.
Economic analysis and how to demonstrate an arm’s length result
If there are internal comparable transactions, whether they are accepted or rejected, it is recommended to perform a comparability analysis before resorting to external sources.
Transactional analysis is preferred over resorting to aggregate or pooled analysis. If an aggregate analysis is used, it is recommended to detail the reasons.
When segmented financial information is used, keep in mind to have robust support and consistency in allocation criteria.
Advance Pricing Agreements (APAs), dispute avoidance and resolution
There is no Advanced Pricing Agreements (APAs) regime applicable in El Salvador.
Exemptions
There are no exemptions for preparing the transfer pricing documentation, regardless size of the company or volume or transactions.
There are exemptions for submitting the TP informative return F-982, if the transactions conducted with related parties does not exceed the amount of US $571,429 in a year.
Contact us
For further information on transfer pricing in EL Salvador please contact:
