Bolivia Transfer Pricing

General reference only. This skill is general tax/accounting reference material for AI-assisted workflows. It has not been reviewed for any specific person's facts, documents, elections, deadlines, residency, filing status, or local procedures. Do not rely on it to file, pay, amend, or take a tax position without review by a qualified professional in the relevant jurisdiction.

The law is Ley N° 843 (Texto Ordenado), arts. 45, 45 bis and 45 ter, as replaced and added by Ley N° 549 of 21 July 2014, inside the corporate income tax (IUE, Título III). The regulation is Decreto Supremo N° 2227 of 31 December 2014. Both are read in the SIN's consolidated edition "Ley N° 843 y Decretos Reglamentarios, Texto Ordenado, Complementado, actualizado al 30/09/2026", which is published for information; the Gaceta Oficial governs. The filing rules are in the SIN's Resolución Normativa de Directorio (RND) N° 10-0008-15 of 30 April 2015, with its art. 8 replaced by RND N° 102600000014 of 16 April 2026. The list of low- or no-tax countries is RND N° 102600000016 of 27 May 2026. Transfer pricing applies for the IUE year, so the 2026 rules apply to years closing in 2026. Amounts are in bolivianos (Bs).

Who this applies to

• Every IUE taxpayer that deals with a related party (Ley 843 art. 45; RND 10-0008-15 art. 2). See bolivia-corporate-income-tax for who pays IUE.
• Related parties (art. 45; DS 2227 art. 2 I). Parties are related when a person, natural or legal, takes part in the management, control or administration of a company or holds capital in it, or when a third party does so in two or more companies. DS 2227 lists these cases:
  1. A Bolivian person takes part, directly or through others, in the management, control or capital of a foreign company, or of a branch or subsidiary of one operating in Bolivia.
  2. A foreign person does the same in a Bolivian company or in a branch or subsidiary in Bolivia.
  3. A person operating in Bolivia has direct or indirect commercial or financial dealings with anyone domiciled or operating in a low- or no-tax country or region. This applies even without any ownership link.
  4. A Bolivian branch or subsidiary deals with its foreign head office, or the other way round.
  5. A Bolivian branch or subsidiary deals with a foreign one of the same head office.
  6. A Bolivian company deals with a foreign one whose owners, shareholders, partners, managers, directors or senior staff are relatives up to the fourth degree by blood or second by marriage.
• Low- or no-tax countries are those on the OECD non-cooperative list and those listed by four or more South American laws (DS 2993, Disposición Adicional Segunda). The SIN keeps the list. RND 102600000016 updated it to 63 countries and regions, for years closing on 30 September 2026 and later. Years closing up to 30 June 2026 still use the 2019 list (RND 101900000002).
• Separate books. Every company, branch or subsidiary in Bolivia keeps its own accounts (DS 2227 art. 2), so that Bolivian-source profit can be found (art. 45).

When to refer. Refer for: a SIN audit or adjustment; customs valuation of related-party imports (DS 2227 Disposición Adicional Única lets Customs ask for a transfer pricing study); cost-sharing and business restructurings; and advance agreements, which the texts read here do not provide for.

Rates, bands and thresholds

Quick answer: related-party prices must be arm's length. Filing depends on the total of related-party operations in the year:

• Bs 15,000,000 or more: Form 601 and a transfer pricing study (EPT);
• Bs 7,500,000 or more, below Bs 15,000,000: Form 601 only;
• below Bs 7,500,000: keep documentation.

Both are due with the IUE return.

Item	Rate or amount	Year	Source
Arm's length rule (Ley 843 art. 45, text of Ley 549)	The value agreed between independent parties in comparable market operations	2026	https://www.impuestos.gob.bo/wp-content/uploads/2026/10/1.-LEY-N%C2%B0-843-09-26-1.pdf
Methods (art. 45 ter; DS 2227 art. 7)	Six: comparable uncontrolled price, resale price, cost plus, profit split, transactional net margin, notorious price in transparent markets; another method only if none fits	2026	same
Value range, lower limit (DS 2227 art. 6 I)	Rinf = Linf + (Lsup - Linf) / 4, where Linf is the sample minimum and Lsup the maximum	2026	same
Value range, upper limit (DS 2227 art. 6 I)	Rsup = Linf + 3 x (Lsup - Linf) / 4	2026	same
Adjustment point when outside the range and the IUE base fell (RND 10-0008-15 art. 10)	R2 = Linf + 2 x (Lsup - Linf) / 4, the middle of the range	2026	https://www.impuestos.gob.bo/wp-content/uploads/2025/11/RND-10-0008-15.pdf
Form 601 and the transfer pricing study (EPT) (RND 10-0008-15 art. 7 a)	Related-party operations in the year of Bs 15,000,000 or more	2026	same
Form 601 only (art. 7 b)	Bs 7,500,000 or more and below Bs 15,000,000	2026	same
Keep documentation only (art. 7 c)	Below Bs 7,500,000	2026	same
Deadline for the EPT and Form 601 (art. 9)	The IUE return deadline: 120 days after the year-end (DS 24051 art. 39)	2026	same
Not filing the EPT or Form 601 on time (art. 12 II rows 1 to 3)	The maximum fine in Ley 2492 art. 162: 5,000 UFV, for each document	2026	same
Filing late but before any SIN action, or filing with errors or gaps (art. 12 II rows 4 to 9)	50% of the maximum: 2,500 UFV	2026	same
Formal-duty fine range (Ley 2492 art. 162 I)	50 UFV to 5,000 UFV	2026	https://www.impuestos.gob.bo/wp-content/uploads/2026/10/2.-LEY-N%C2%B0-2492-09-26-2.pdf
Omission of payment on an adjustment (Ley 2492 art. 165, text of Ley 1448)	60% of the updated omitted tax	2026	http://gacetaoficialdebolivia.gob.bo/normas/verGratis_gob/168844
Limitation period (Ley 2492 art. 59, text of Ley 1733 of 27 May 2026)	4 years; plus 2 only for failure to register or the wrong regime. The former 2-year extension for dealings with low-tax countries is no longer in the text	2026	http://gacetaoficialdebolivia.gob.bo/normas/verGratis_gob/281228

The base

The rule. In commercial or financial operations between related parties, the transaction value must be the one independent parties would have agreed in comparable market operations (art. 45). The SIN may check this and adjust or revalue when the agreed value, whatever its legal form, does not match economic reality or lowers Bolivian tax (art. 45 bis).

Comparability (DS 2227 art. 5). Two operations are comparable when no difference between them materially affects the price or the profit margin, or when such differences can be removed by technically justified adjustments. Look at:

• the characteristics of the goods or services;
• the functions of each party, with the risks assumed and the assets used;
• the contract terms;
• the market and other economic factors;
• business strategies, such as market penetration.

Methods (art. 45 ter; DS 2227 art. 7). Use the method that best fits the nature, economic reality and circumstances of the case.

• Comparable uncontrolled price: the price of the same or similar goods or services between independent parties.
• Resale price: the resale price less the usual gross margin on net sales.
• Cost plus: the cost plus the usual gross margin on cost of sales.
• Profit split: the joint operating profit divided by a criterion independent parties would use. A residual split is allowed after a routine return.
• Transactional net margin: a net margin on assets, costs, sales, expenses or cash flow. Use it when gross margins cannot be identified or price data is unreliable.
• Notorious price in transparent markets: for imports and exports of goods, the price quoted on international markets or public exchanges on the shipment date, with or without an intermediary.

The value range (DS 2227 art. 6). From the comparables, take the minimum (Linf) and maximum (Lsup).

• The range: from Rinf = Linf + (Lsup - Linf) / 4 to Rsup = Linf + 3 x (Lsup - Linf) / 4. That is the middle half of the spread between the lowest and highest comparable.
• Inside the range: the price is treated as arm's length.
• Outside the range: the relationship is presumed to have affected the price. If that lowered the IUE base, the value is adjusted to the midpoint R2 = Linf + 2 x (Lsup - Linf) / 4 (RND 10-0008-15 art. 10).
• What the SIN adjusts: costs, expenses, deductions, income, profits or losses in the IUE return (DS 2227 art. 8). It sets out the new value, the comparability analysis and the method in the Vista de Cargo.

Intra-group services (DS 2227 art. 9). Management, legal, accounting, financial, technical and similar services from a related party are valued under the same rules.

• Allocation: allocate directly where the service received can be identified. Otherwise split the total by the nature of the service and the benefit each party gets or could get.
• Deductibility: the expense is deductible only if the service was actually rendered and is linked to the taxed activity. The general non-deductible items in DS 24051 art. 18 still apply.

Payments abroad. Whatever the price, Bolivian-source amounts paid to a foreign related party also bear IUE-BE withholding at 12.5% (bolivia-corporate-income-tax).

Deadlines and filing

Steps, in the order the filer meets them:

1. Add up the year's related-party operations. Include every commercial and financial operation with each related party, and with anyone in a listed low- or no-tax country. Convert foreign currency at the BCB official rate on each operation date (RND 10-0008-15 art. 3 II). This total decides the obligation (art. 7).
2. Below Bs 7,500,000: keep the documents that show the prices were at market, or that adjustments were made. Nothing is filed.
3. Bs 7,500,000 or more: fill in Form 601, the information return on operations with related parties, in the SIN's Da Vinci application. Send it through the Da Vinci module of the Oficina Virtual (RND 10-0008-15 arts. 5, 6 and 8 II).
4. Bs 15,000,000 or more: also prepare the transfer pricing study (EPT) in Spanish and in bolivianos, signed by the legal representative (art. 3 I). It must contain at least:
   • an index;
   • an executive summary: the parties, the type of relationship, the operations and the method;
   • a functional analysis: the parties' background, the group structure, the relationship, activities and markets, strategies, contracts with functions, assets and risks, and financial ratios;
   • an economic analysis: the operations and balances, the method chosen and why, the comparables and their sources, the value range, the results and any adjustment;
   • conclusions (art. 4).
5. Submit the EPT in the SIAT as a signed PDF together with the year-end financial statements. This is the April 2026 text of art. 8 I, which replaced the earlier paper filing at the district office.
6. Deadline: both by the IUE return deadline, 120 days after the year-end (art. 9; DS 24051 art. 39). For a 31 December 2026 year-end that is 30 April 2027. The SIN can extend it: for 31 December 2025 year-ends, RND 102600000014 and RND 102600000017 moved the digital filing of the EPT and Form 601 to 30 June 2026.
7. Report any adjustment you make yourself in the IUE return (bolivia-corporate-income-tax, Form 500). Paying the fine does not remove the duty to file (art. 12 III).

Penalties and interest

• Formal duties (RND 10-0008-15 art. 12; Ley 2492 art. 162): not filing the EPT or Form 601 on time is fined at the maximum of art. 162, 5,000 UFV for each document. Filing late but before any SIN action, or filing with errors or gaps, is fined at 50%, 2,500 UFV. The fine in bolivianos is the UFV value on the payment date.
• Tax on an adjustment: the extra IUE is omitted tax, expressed in UFV at the original due date, with interest of 4% a year for years 1 to 4, 6% for 5 to 7 and 10% from year 8 (Ley 2492 art. 47). Omission of payment adds 60% of the updated omitted tax (art. 165). That fine is extinguished if paid by the twentieth day after the Vista de Cargo (art. 157), and reduced by 80%, 60% or 40% at later stages (art. 156).
• Limitation (art. 59, text of Ley 1733): 4 years from 1 January after the IUE due date.

Cross-border points

• Any dealing with a listed low- or no-tax country is a related-party operation, even without ownership (DS 2227 art. 2 I 3). Check the counterparty's country against the list that fits the year-end: the RND 102600000016 annex from 30 September 2026 year-ends, the 2019 list before. The 2026 list includes, among others, Andorra, Angola, Bahamas, Bahrain, Belize, Bermuda, the British Virgin Islands, the Cayman Islands, Cyprus, Gibraltar, Hong Kong, Jersey, Liechtenstein, Macao, Monaco, Puerto Rico, Seychelles, Sri Lanka, Oman, Trinidad and Tobago, Vanuatu and Yemen.
• Head office and branches. Operations between a Bolivian branch and its foreign head office or sister branches are related-party operations (cases 4 and 5).
• Customs. For related-party imports, Customs may ask for a transfer pricing study to show the relationship did not affect the customs value (DS 2227 Disposición Adicional Única, amending DS 25870 art. 251).

Two worked examples that recompute

Example 1: distributor outside the range, adjusted to the midpoint

Distribuidora Andina SA (31 December year-end) buys all its stock from its foreign parent. Its 2026 net sales are Bs 20,000,000 and its operating profit Bs 600,000, an operating margin of 3%. Purchases from the parent are Bs 18,000,000. A transactional net margin analysis finds comparable distributors with operating margins from 2% (Linf) to 10% (Lsup).

• Related-party operations: Bs 18,000,000, at least Bs 15,000,000, so it files Form 601 and an EPT by 30 April 2027.
• Range: Rinf = 2 + (10 - 2) / 4 = 4%; Rsup = 2 + 3 x 8 / 4 = 8%.
• 3% is below 4%, so the price is presumed affected. It lowered the IUE base.
• Adjust to the midpoint: R2 = 2 + 2 x 8 / 4 = 6%. Adjusted operating profit: 6% x 20,000,000 = Bs 1,200,000. Adjustment Bs 600,000.
• Extra IUE at 25%: Bs 150,000. If the company makes the adjustment itself in its Form 500, no omission fine arises. If the SIN finds it, the Bs 150,000 is omitted tax with UFV updating, interest and the 60% fine.
• The edge: at a 4.5% margin the company is inside the range. No adjustment is made, even though 4.5% is below the midpoint.

name: Distribuidora Andina SA, TNMM range and midpoint adjustment (2026)
inputs:
  sales: 20000000
  profit: 600000
  linf: 0.02
  lsup: 0.10
  ops: 18000000
steps:
  - margin: profit / sales
  - rinf: linf + (lsup - linf) / 4
  - rsup: linf + 3 * (lsup - linf) / 4
  - r2: linf + 2 * (lsup - linf) / 4
  - adjusted_profit: r2 * sales
  - adjustment: adjusted_profit - profit
  - extra_iue: adjustment * 0.25
  - ept_required: floor(min(ops / 15000000, 1))
expected:
  margin: 0.03
  rinf: 0.04
  rsup: 0.08
  r2: 0.06
  adjusted_profit: 1200000
  adjustment: 600000
  extra_iue: 150000
  ept_required: 1

Example 2: which filing does a group company need? Worked at three totals

Servicios Integrales SRL pays its foreign sister company for management services. It also buys from an unrelated supplier in a listed low-tax territory. Both count towards the total (DS 2227 art. 2 I cases 3 and 5). The fines are in UFV.

• Case A: Bs 9,000,000 of related operations (Bs 6,500,000 services plus Bs 2,500,000 low-tax purchases). This is at least Bs 7,500,000 and below Bs 15,000,000, so Form 601 only. If the company forgets it, the fine is 5,000 UFV. Filed late before any SIN action, it is 2,500 UFV.
• Case B: Bs 6,500,000 (the low-tax purchases moved to a supplier outside the list). Below Bs 7,500,000, so nothing is filed. Keep the documents that support market prices and show the services were really rendered (DS 2227 art. 9).
• Case C: Bs 16,000,000. Form 601 and the EPT. Missing both costs 5,000 UFV each: 10,000 UFV.
• What decides it is the total, not the size of any one operation. A supplier's move onto or off the low-tax list can move the company between cases.

name: Servicios Integrales SRL, filing tier at three totals (2026)
inputs:
  services: 6500000
  lowtax: 2500000
  total_c: 16000000
  max_fine_ufv: 5000
steps:
  - total_a: services + lowtax
  - form601_a: floor(min(total_a / 7500000, 1))
  - ept_a: floor(min(total_a / 15000000, 1))
  - total_b: services
  - form601_b: floor(min(total_b / 7500000, 1))
  - form601_c: floor(min(total_c / 7500000, 1))
  - ept_c: floor(min(total_c / 15000000, 1))
  - fine_a_missing: form601_a * max_fine_ufv
  - fine_a_late: form601_a * max_fine_ufv * 0.5
  - fine_c_missing: (form601_c + ept_c) * max_fine_ufv
expected:
  total_a: 9000000
  form601_a: 1
  ept_a: 0
  total_b: 6500000
  form601_b: 0
  form601_c: 1
  ept_c: 1
  fine_a_missing: 5000
  fine_a_late: 2500
  fine_c_missing: 10000

Ask the client first

1. Who the related parties are and how: ownership, management, head office or branch, family links (case 6), and any counterparty in a listed low- or no-tax country.
2. The year-end, which sets the deadline and which low-tax list applies (2019 list up to 30 June 2026, the 2026 list from 30 September 2026).
3. The total of related-party operations in the year, in bolivianos at BCB rates on each date. This sets the Bs 7,500,000 and Bs 15,000,000 tiers.
4. What the operations are (goods, services, loans, royalties) and which method and comparables support the prices.
5. For intra-group services: evidence the service was rendered, the benefit, and the allocation key.
6. Whether goods are imported from related parties (customs valuation) and whether payments abroad bear IUE-BE.

Sources

Source	URL	Read on
SIN, Ley N° 843 y Decretos Reglamentarios, Texto Ordenado, Complementado, actualizado al 30/09/2026: read Ley 843 arts. 45, 45 bis and 45 ter with the DS 2993 note (PDF pp. 104 to 106) and DS 2227 arts. 1 to 11 and Disposición Adicional Única (range formula on p. 144)	https://www.impuestos.gob.bo/wp-content/uploads/2026/10/1.-LEY-N%C2%B0-843-09-26-1.pdf	2026-11-11
SIN, RND N° 10-0008-15 of 30 April 2015, Precios de transferencia en operaciones entre partes vinculadas: arts. 1 to 12	https://www.impuestos.gob.bo/wp-content/uploads/2025/11/RND-10-0008-15.pdf	2026-11-11
SIN, RND N° 102600000014 of 16 April 2026: new art. 8 of RND 10-0008-15 (EPT through the SIAT), Form 605 contents, extensions for 2025 year-ends	https://www.impuestos.gob.bo/wp-content/uploads/2026/04/RND-102600000014.pdf	2026-11-11
SIN, RND N° 102600000016 of 27 May 2026: updated list of low- or no-tax countries and regions (63 entries) and its transitional rule	https://www.impuestos.gob.bo/wp-content/uploads/2026/05/RND-No-1026000000016.pdf	2026-11-11
SIN, RND N° 102600000017 of 27 May 2026: extension to 30 June 2026 of the digital EPT and Form 601 for 31 December 2025 year-ends	https://www.impuestos.gob.bo/wp-content/uploads/2026/05/RND-No-1026000000017.pdf	2026-11-11
SIN, Ley N° 2492 Código Tributario Boliviano, Texto Ordenado, actualizado al 30/09/2026: arts. 47, 156, 157, 162 and 165	https://www.impuestos.gob.bo/wp-content/uploads/2026/10/2.-LEY-N%C2%B0-2492-09-26-2.pdf	2026-11-11
Gaceta Oficial, Ley N° 1448 of 25 July 2022 (HTML text): new art. 165 of Ley 2492 (60%)	http://gacetaoficialdebolivia.gob.bo/normas/verGratis_gob/168844	2026-11-11
Gaceta Oficial, Ley N° 1733 of 27 May 2026 (HTML text): new arts. 59 and 60 of Ley 2492	http://gacetaoficialdebolivia.gob.bo/normas/verGratis_gob/281228	2026-11-11

Not yet confirmed: any SIN resolution after RND 102600000014 that changes the Bs 7,500,000 and Bs 15,000,000 tiers or the content of the EPT; the Form 601 field list and the current Da Vinci version; the 2019 low-tax list (RND 101900000002) for year-ends up to 30 June 2026; whether the SIN offers advance pricing agreements or corresponding adjustments; treaty mutual-agreement procedures; the UFV value in bolivianos on any given date (Banco Central de Bolivia, not read).