Data points
- Related-party transactions that trigger the F-982 report[2]
- USD 571,429
- After fiscal year end to file the F-982, so 31 March for calendar-year filers[2]
- 3 months
- Of equity, the penalty for a missing, late or non-compliant F-982[2]
- 0.5%
- Floor on that penalty, three monthly minimum wages[2]
- USD 1,226.40
- Share capital or voting rights that makes two parties related[2]
- 25%
- No master file rule was found in El Salvador's primary texts[1]
- No master file
El Salvador has no master file and no local file by those names. It has one report filed with the tax authority, and a transfer pricing study that has to exist before that report goes in.
The four facts to know:
- The report is required once related-party or low-tax-jurisdiction transactions reach USD 571,429 in the fiscal year, counted one by one or together.
- It is due within three months of fiscal year end, so 31 March for a calendar-year taxpayer.
- A transfer pricing study has to be in place before the report is filed, even though the study itself is not submitted on the calendar.
- Missing, late or non-compliant filing costs 0.5% of equity, with a floor of USD 1,226.40.
What transfer pricing documents does El Salvador require?
One filed report and one supporting study. The report is the F-982, the Informe de Operaciones con Sujetos Relacionados, and the tax authority behind it is the Direccion General de Impuestos Internos. El Salvador never adopted the three-tier documentation standard, because it does not sit in the body that set it: it is absent from the 148-jurisdiction Inclusive Framework membership list updated in December 2025[1].
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| Question | El Salvador in 2026 | Source |
|---|---|---|
| Master file required | Not confirmed. No rule found | OECD |
| Local file required | Conditionally. A transfer pricing study for every F-982 filer | Ministerio de Hacienda, El Salvador |
| F-982 threshold | USD 571,429 of related-party or preferential-regime transactions | Asamblea Legislativa, El Salvador |
| F-982 deadline | Within three months of fiscal year end | Asamblea Legislativa, El Salvador |
| F-982 penalty | 0.5% of equity, floor of three monthly minimum wages | Asamblea Legislativa, El Salvador |
| Country-by-country reporting | No confirmed obligation | OECD |
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Does El Salvador require a master file or a local file?
No master file obligation was found in the primary texts, and El Salvador is not an OECD member country[3] either, so it never committed to the master file standard through membership. We say not confirmed rather than no, because what is missing is a rule, not a statement that there is none.
The local file has a substance equivalent. A taxpayer that files the F-982 needs a transfer pricing study and supporting records showing that related-party pricing is arm's length, and that work has to be finished before the report is filed. Whether the study goes in with the report or is held and produced on request is not confirmed.
What is the F-982 report and who has to file it?
The F-982 is El Salvador's own related-party return. Any taxpayer whose related-party or preferential-regime transactions reach USD 571,429 or more in a fiscal year has to file it within the first three months after year end. The threshold is measured on transactions taken one by one or added together, and the statute reads "equal to or greater than", so a company landing exactly on the number is in scope.
The tax authority publishes a user manual for the form[4], which is the practical guide to filling it in. The report asks for each related-party transaction, the counterparty, the amount and the method used to price it.
Does El Salvador require country-by-country reporting?
No country-by-country rule was found, and no notification rule either. El Salvador sits outside the Inclusive Framework, so it carries none of the minimum-standard commitments that put country-by-country reporting into other countries' law.
Treat this as absence of evidence rather than proof of absence. If a Salvadoran source states a rule, it overrides this page. For a parent that files country-by-country reports elsewhere, the practical position today is that El Salvador wants the F-982 and nothing above it.
When is El Salvador transfer pricing documentation due?
Within the first three months after fiscal year end. For a calendar-year taxpayer the window runs 1 January to 31 March, and it moves to the next business day when 31 March falls on a holiday. The supporting study is not on the calendar, but it has to exist by the time the report is filed.
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| Obligation | Trigger | Deadline | Source |
|---|---|---|---|
| F-982 related-party report | Related-party or preferential-regime transactions of USD 571,429 or more in the fiscal year | Within three months of fiscal year end, so 31 March for calendar-year filers | Asamblea Legislativa, El Salvador |
| Transfer pricing study | Any taxpayer that has to file the F-982 | In place before the F-982 is filed | Ministerio de Hacienda, El Salvador |
A Ministry of Finance calendar entry showed 31 March 2025 for the F-982, which matches the three-month rule. The Ministry of Finance publishes the filing calendar[5] each year, and that is the date to work to.
What language and currency does the documentation use?
US dollars. The dollar has been legal tender since 2001 and is the functional tax and accounting currency, so the threshold and the penalties are already stated in the currency you file in. The filing language rule is not confirmed. Spanish is the official language and the tax authority works in it, so Spanish is the working assumption rather than a sourced rule.
What are the penalties for getting El Salvador transfer pricing wrong?
One penalty covers three failures: not filing the F-982, filing it late, and filing it without the required specifications. It is 0.5% of the taxpayer's equity, with a floor of three monthly minimum wages. The equity base is the patrimonio or capital contable on the balance sheet, net of unrealized asset revaluation surplus.
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| Failure | Penalty | Floor | Source |
|---|---|---|---|
| F-982 not filed, filed late, or non-compliant | 0.5% of equity, net of unrealized revaluation surplus | Three monthly minimum wages, USD 1,226.40 at the USD 408.80 commerce and services wage | Asamblea Legislativa, El Salvador |
The USD 408.80 monthly minimum wage for commerce and services was set in May 2025, so the cash floor moves whenever that wage moves.
What is a foreign parent exposed to in El Salvador?
A fine that scales with the subsidiary's balance sheet rather than with the transaction. Because the penalty is 0.5% of equity, a well capitalised subsidiary that misses the report can pay a large fine over a small deal, and capitalising the entity properly makes the exposure worse rather than better.
The second trap is the preferential-regime rule. Dealings with a low-tax or no-tax jurisdiction count toward the USD 571,429 threshold even when the counterparty is unrelated, so a group that only counts intercompany flows can file nothing and still be over the line.
How does El Salvador differ from the OECD baseline?
On almost every point. It is outside both the OECD and the Inclusive Framework, it files a report instead of keeping files for an audit, and it has no confirmed three-tier regime. Costa Rica, Guatemala, Honduras and Panama all appear on the Inclusive Framework list. El Salvador does not.
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| OECD baseline | El Salvador in 2026 | Source |
|---|---|---|
| OECD membership or an Inclusive Framework commitment | Neither | OECD |
| Master file, local file and country-by-country report | No confirmed three-tier regime | OECD |
| Files kept and produced on request | One report, filed within three months of year end | Asamblea Legislativa, El Salvador |
| Master file above a revenue threshold | Not confirmed | OECD |
| Country-by-country reporting as a minimum standard | No confirmed obligation | OECD |
| OECD Transfer Pricing Guidelines followed | Not confirmed | OECD |
How we help with El Salvador transfer pricing
El Salvador is easy to miss precisely because it looks nothing like the regimes around it. One report, one hard threshold, a three-month window and a fine that grows with your balance sheet. We build the study and the benchmarking behind it, keep the intercompany agreements aligned with the pricing, and file the report inside the window. See how our transfer pricing software works.
Book a demo to map your El Salvador exposure before the 31 March deadline.
Official sources
5 sources
- 1.OECD. Inclusive Framework on BEPS composition (5 December 2025)
- 2.Asamblea Legislativa, El Salvador. Codigo Tributario de El Salvador (articles 62-A, 124-A, 199-C and 244)
- 3.OECD. Members and partners of the OECD
- 4.Ministerio de Hacienda, El Salvador. F-982 user manual, Direccion General de Impuestos Internos
- 5.Ministerio de Hacienda, El Salvador. Ministerio de Hacienda, tax filing calendar and taxpayer portal
Article by
Sam Suechting
Head of Product, Commenda
Sam is a seasoned expert in sales tax, leading Commenda's effort to build the worlds most comprehensive database of global tax rules and business regulations. At Silverhaze Partners, he worked in early-stage venture capital, where he saw firsthand how tax complexity and regulatory friction hold back startups from scaling internationally. That experience now powers his work at Commenda-bringing clarity, precision, and real-world insight to one of the most frustrating parts of doing business globally.
Disclaimer: Commenda and its affiliates do not provide tax, accounting, or legal advice. This material has been prepared for informational purposes only, and is not intended to provide or be relied on for tax, accounting, or legal advice. You should consult your own tax, accounting, and legal advisors before engaging in any related activities or transactions.
