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13.4.3. Documentation Requirements

Disclosure Requirements

Taxpayers are required to file TP disclosure along with the statutory financial statements and the annual tax return, based on the annual transaction values with the related parties, which are as follows:

  • Taxpayers with annual transactions value exceeding BOB 15 million are required to file a sworn informative statement and a full TP report;
  • Taxpayers with annual transactions value between BOB 7.5 million and BOB 15 million are required to file a sworn information statement and a brief report of transactions with related parties; and
  • Taxpayers with annual transactions value up to BOB 7.5 million are not required to file TP disclosure, but are required to maintain TP documentation demonstrating their compliance with the arm's length principle.

Standard Documentation

The TP rules require a taxpayer to maintain contemporaneous TP documentation. Effective 1 May 2015, the TP documentation should include the following information:

  • A description of the taxpayer's industry and markets in which it operates;
  • A description of the organizational and corporate structure of the taxpayer's group;
  • Details of related parties, including the type of relationship and the transactions performed;
  • The business strategies and policies for determining pricing levels;
  • The transfer pricing method selected;
  • The transactions, agreements, or contracts concluded with related parties, including a description of the activities performed, assets used, and risks assumed by both parties;
  • The financial indicators used in determining the arm's length price, including profitability ratios, debt ratios, interest rates, and methods for calculating royalties for use of intangibles;
  • The amount of related party transactions, including outstanding balances; and
  • A comparability analysis, including a description of the comparable sources.

Language of Documentation

The TP documentation is required to be maintained in the Spanish language.

Country-by-Country (CbC) Reporting

Bolivia has to date not introduced a Country-by-Country reporting requirement and has not joined the OECD's Inclusive Framework, membership of which presupposes a commitment to implement the BEPS minimum standards, including Country-by-Country reporting.