Worldwide transfer pricing reference guide 2014

Bolivia (continued)
Documentation deadlines
The income tax return is due within four months of the fiscal year end. There are no specific requirements to include details about market
prices in the income tax return.
Statute of limitations on transfer pricing assessments
There is no specific statute of limitations for transfer pricing adjustments; rather, the general regime applies. Until August 2012,
the general statute of limitation was four years calculated from 1 January of the year following the year in which the tax payment is due.
In September 2012, Law 291 (modification of Article 59° of the Bolivian Tributary Code) was issued, modifying the statute of limitation
rules. However, this change is unclear as there are several interpretations in this regard.
Nevertheless, the largely accepted position involves that this new law has a prospective application, that is, tax authorities may control,
carry out tax audits, verify and supervise the fulfillment of tributary formal and material obligations for the following range of years:
• 4 years in 2012
• 5 years in 2013
• 6 years in 2014
• 7 years in 2015
• 8 years in 2016
• 9 years in 2017
• 10 years in 2018
Return disclosures/related party disclosures
Not required.
Transfer pricing-specific returns
Not applicable.
Frequency of tax audit and transfer pricing scrutiny by the tax authority
Not applicable.
APA opportunity
Not applicable.
Expected reaction to OECD Report on BEPS
There has not been any reaction from the tax authorities up until January 2014.
Worldwide transfer pricing reference guide
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