In 2026, transfer pricing compliance has become a critical matter for Spanish groups with a presence in Latin America. We are coming off a 2025 in which several Latin American countries progressively aligned with OECD BEPS standards and strengthened their transfer pricing documentation requirements. The outcome is clear: more tax audits, more information requests, and an increasing focus on related‑party transactions.
The start of 2026 confirms this trend. Guatemala’s accession to the OECD/G20 Inclusive Framework on BEPS, together with the progress of Latin American tax administrations in the intensive use of technology, data analytics, predictive models, automation, and international information exchange, point to a clear scenario: more control, more technology, and virtually no room for improvisation.
In this environment, anticipation is no longer just advisable; it has become essential. Having clear information, a robust economic analysis, and a well‑structured tax calendar for each country is critical to avoid risks, penalties, and unexpected audits. Today, for any Spanish multinational, visibility over compliance obligations and the early preparation of transfer pricing documentation are no longer merely good practices but a structural component of tax management in a fully digitalised landscape.
Below is a summary of the most relevant first‑quarter 2026 deadlines that Spanish multinationals should keep on their radar to ensure timely transfer pricing compliance in Latin America.
February
March
In short, in a 2026 marked by more intensive enforcement, greater use of technology, and increasing requirements across LATAM jurisdictions, having a clear transfer pricing strategy is indispensable for any Spanish group seeking to operate without unexpected disruptions.
BDO, with a presence in more than 160 countries and with specialised teams across Latin America, supports clients so that compliance is not only an obligation, but also a genuine competitive advantage.
For more information on these upcoming deadlines, please consult your regular BDO contact or the authors of this article.
Flavio Sanchez Huaman
Mónica Natalia Herrera Rubiano
BDO in Spain
* The deadlines in the table apply to taxpayers with a calendar fiscal year, i.e., a year‑end of 31 December 2025.
* In jurisdictions where documentation does not have a mandatory filing deadline, it must be prepared and kept available to the Tax Administration. In addition, its content may also be required to complete informative filings.
** To be filed together with the Corporate Income Tax return.
The start of 2026 confirms this trend. Guatemala’s accession to the OECD/G20 Inclusive Framework on BEPS, together with the progress of Latin American tax administrations in the intensive use of technology, data analytics, predictive models, automation, and international information exchange, point to a clear scenario: more control, more technology, and virtually no room for improvisation.
In this environment, anticipation is no longer just advisable; it has become essential. Having clear information, a robust economic analysis, and a well‑structured tax calendar for each country is critical to avoid risks, penalties, and unexpected audits. Today, for any Spanish multinational, visibility over compliance obligations and the early preparation of transfer pricing documentation are no longer merely good practices but a structural component of tax management in a fully digitalised landscape.
Below is a summary of the most relevant first‑quarter 2026 deadlines that Spanish multinationals should keep on their radar to ensure timely transfer pricing compliance in Latin America.
Key Deadlines
February| Country | Deadline* | Formal obligations |
| Nicaragua | Taxpayer’s documentation must be available at the time the corporate income tax return is filed -- 28 February 2026 | Local File |
March
| Country | Deadline* | Formal obligations |
| El Salvador | 31 March 2026 | Transfer Pricing Informative Return (Form N°982) |
| Taxpayer’s documentation must be retained by the taxpayer | Local File | |
| Guatemala | 31 March 2026** | Transfer Pricing Informative Return |
| Taxpayer’s documentation must be retained by the taxpayer | Local File | |
| Mexico | 31 March 2026 | ISSIF (Information on tax position) |
| 15 May 2026 | Annex 9 (DIM) | |
| Transfer Pricing Informative Return |
In short, in a 2026 marked by more intensive enforcement, greater use of technology, and increasing requirements across LATAM jurisdictions, having a clear transfer pricing strategy is indispensable for any Spanish group seeking to operate without unexpected disruptions.
BDO, with a presence in more than 160 countries and with specialised teams across Latin America, supports clients so that compliance is not only an obligation, but also a genuine competitive advantage.
For more information on these upcoming deadlines, please consult your regular BDO contact or the authors of this article.
Flavio Sanchez Huaman
Mónica Natalia Herrera Rubiano
BDO in Spain
* The deadlines in the table apply to taxpayers with a calendar fiscal year, i.e., a year‑end of 31 December 2025.
* In jurisdictions where documentation does not have a mandatory filing deadline, it must be prepared and kept available to the Tax Administration. In addition, its content may also be required to complete informative filings.
** To be filed together with the Corporate Income Tax return.