Expert Panama transfer pricing documentation — Form 930 preparation, comparability analysis and DGI defense. Former DGI official with direct TP expertise.
Panama's transfer pricing rules under Decree 390 require companies with related-party transactions exceeding B/.3 million to prepare contemporaneous Form 930 documentation meeting OECD standards.
Our founding attorney was a DGI official specializing in transfer pricing — giving us unique insight into exactly how the DGI examines Form 930 files and what triggers assessments.
Deep insight into Panama's tax authority processes.
Master in Public Administration — law, economics and policy.
You always deal directly with the attorney handling your case.
Licensed attorney in the Republic of Panama.
"Having worked inside the DGI's transfer pricing unit taught me exactly what they look for — and exactly what documentation gaps lead to assessments."
— Lic. José Manuel Góndola Escudero · Idoneidad No. 17,005Complete Form 930 preparation with all required schedules and contemporaneous documentation.
Characterization of related-party transactions by function, assets and risks.
Benchmarking using Panama and international comparable databases.
Selection and documentation of the most appropriate TP method for each transaction type.
Defense of Form 930 filings under DGI examination. Preparation of technical responses.
Negotiation of APA with the DGI for prospective certainty on TP methodology.
We identify all related-party transactions subject to Panama TP rules.
Functional analysis, risk assessment and method selection for each transaction type.
Preparation of the complete Form 930 and supporting TP documentation file.
Filing with the DGI and defense support if the file is subject to examination.
Annual TP documentation for Panama manufacturing company with parent in Colombia and US.
Documentation of intercompany loan interest rates using comparable uncontrolled price method.
Defense of Form 930 under DGI audit — technical responses and comparability arguments.
Companies that carry out transactions with related parties (parent, subsidiaries, affiliates) exceeding B/.3 million in the fiscal year.
Panama accepts all OECD methods: comparable uncontrolled price, resale price, cost plus, transactional net margin and profit split.
Automatic fines for non-filing, plus the DGI can presume transfer prices and issue substantial additional ISLR assessments.
The documentation must include a functional analysis, economic analysis, method selection and benchmarking — contemporaneous with the transactions.
An Advance Pricing Agreement is a bilateral agreement with the DGI that fixes the TP methodology and pricing for future transactions, providing certainty and protection from assessments.
Confidential consultation. We assess your related-party transactions and provide a complete TP plan.