Worldwide transfer pricing reference guide 2014

Honduras (continued)
Statute of limitations on transfer pricing assessments
The statute of limitations on general tax assessments is 5 to 10 years. The term is extended with the filing of an amended return.
Return disclosures/related party disclosures
There are no related party disclosures that are to be made on general income tax returns.
Transfer pricing-specific returns
Taxpayers are required to document and file information about their transactions with related parties on an annual basis by the time the
Income Tax Return is filed. However, it is not clear in the law whether the documentation or a transfer pricing information return should
be filed. This is expected to be clarified through further regulations.
Frequency of tax audit and transfer pricing scrutiny by the tax authority
The likelihood of a general tax audit is currently categorized as high. The likelihood of transfer pricing assessments as part of a general
tax audit is considered low. The DEI has not yet initiated any tax audits regarding transfer pricing because the regulations come into
force as of tax year 2014. In case transfer pricing is scrutinized, the likelihood that the transfer pricing methodology will be challenged is
unknown.
APA opportunity
APAs are contemplated under the provisions of the Decree 232–2011. Taxpayers can request an APA for a maximum of five years.
However, the corresponding regulations have not yet been enacted.
Expected reaction to OECD Report on BEPS
As transfer pricing provisions in Honduras have just been enacted and will be effective from tax year 2014, there is no expectation of
immediate or short-term reaction regarding the specialized topics covered in the OECD Report on BEPS.
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