Transfer Pricing in El Salvador
The rules
- The market price rule applies to every related-party transaction, whatever its size. The USD 571,429 figure only decides who files Form F-982.
- Taxpayers may use the methods in the Tax Code and in the OECD Transfer Pricing Guidelines. The interquartile range is accepted, and values outside it can be adjusted to the median.
- Form F-982 (version 4) is filed online through the DGII online services, within three months of the year end. For 2025 the Tax Administration set 7 April 2026 because of the Holy Week holidays.
- Supporting documentation is kept for ten years.
Source: EY: El Salvador updates transfer pricing information return and guidelines; Deloitte: Form F-982 filing for 2025 due 7 April 2026; Grupo Consultor EFE: Transfer pricing in El Salvador1,2,4
Penalties
Not filing Form F-982, filing late or filing it incomplete carries a fine of 0.5% of equity shown on the balance sheet, less unrealised revaluation surplus, and never less than three monthly minimum wages.1
Thin capitalisation
Interest and other financing costs paid to a related lender, or to one in a tax haven or preferential regime, are not deductible when the debt exceeds three times the borrower’s average equity. El Salvador has no controlled foreign company (CFC) rules and no group taxation: each company files on its own.3
Frequently Asked Questions
Does El Salvador have transfer pricing rules?
Yes. Under Article 62-A of the Tax Code, transactions with related parties and with entities in tax havens and preferential regimes must be priced at market value.
When must Form F-982 be filed?
When related-party transactions reach USD 571,429 in a year, they are reported on Form F-982, filed online within three months of the year end.
What is the penalty for not filing Form F-982?
A fine of 0.5% of equity shown on the balance sheet, less unrealised revaluation surplus, and never less than three monthly minimum wages.
Sources
- EY: El Salvador updates transfer pricing information return and guidelines
- Deloitte: Form F-982 filing for 2025 due 7 April 2026 (in Spanish)
- PwC Worldwide Tax Summaries: El Salvador, group taxation
- Grupo Consultor EFE: Transfer pricing in El Salvador (in Spanish)
Figures checked 8 November 2026. Prepared by InvestSalvador.com for general information. It is not investment, tax or legal advice; please confirm details with a qualified adviser before acting.
