Data points
- Form 545 deadline for calendar-year taxpayers[3]
- 30 Apr 2026
- Related-party transactions above which a small taxpayer files Form 545[4]
- USD 1m
- Group revenue that triggers country-by-country reporting[1]
- EUR 750m
- Master file requirement in force in Honduras[1]
- None
- Capital or voting rights above which two parties are related[2]
- 50%
- Top fixed fine, charged with 30% of the adjustment[1]
- USD 20,000
- Penalty on an adjustment for understating the tax base[1]
- 15%
- After fiscal year end to file the country-by-country report[1]
- 12 months
Honduras splits transfer pricing into three separate obligations, and only one of them has a fixed date. A group that already prepares a master file and a local file everywhere else still has to file Form 545 here, and still has to produce a local study the moment the tax office asks.
The four facts to know:
- There is no master file requirement yet. The local study is kept, not filed, and handed over only on request.
- Form 545, the annual transfer pricing return, is due 30 April 2026 for calendar-year taxpayers. Small taxpayers file it only above USD 1,000,000 of related-party transactions.
- Country-by-country reporting starts at EUR 750 million of consolidated group revenue, filed within 12 months of year end.
- Documentation fines run from USD 5,000 to USD 20,000, on top of 15% of any adjustment to the tax base.
What transfer pricing documentation does Honduras require?
Three things, and they behave differently. A local transfer pricing study is kept on file and produced when the Servicio de Administración de Rentas (SAR), the Honduran tax office, requests it. Form 545 is filed every year on a fixed date. A country-by-country report is filed only by large groups. There is no master file obligation, as the OECD transfer pricing country profile for Honduras[1] published in May 2025 records.
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| Obligation | Who it applies to | Status for 2026 | Source |
|---|---|---|---|
| Master file | Not applicable | Not yet mandatory | OECD |
| Local transfer pricing study | Taxpayers with related-party transactions | Kept, produced on request | Servicio de Administración de Rentas, Honduras |
| Form 545 informative return | Medium and large taxpayers, and small taxpayers above USD 1,000,000 | Due 30 April 2026 | Servicio de Administración de Rentas, Honduras |
| Country-by-country report | Groups above EUR 750 million of revenue | Within 12 months of year end | Servicio de Administración de Rentas, Honduras |
Who do Honduras transfer pricing rules apply to?
Two parties are related when direct or indirect participation in capital or voting rights passes 50%. Common management or control counts as well, and so do exclusivity contracts, economic dependence, close family ties and residence in a listed tax haven. A foreign parent that owns its Honduran entity outright is squarely in scope.
Official wording diverges on the ownership test, which matters at exactly 50%. The transfer pricing law published by the SAR[2] reads "more than fifty percent", while the SAR's own Form 545 help guide lists ownership of "50% or more". Treat a flat 50% holding as related until the SAR tells you otherwise.
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| Related party test | Threshold | Source |
|---|---|---|
| Direct or indirect capital or voting rights | More than 50%, or 50% or more on the SAR form guide | Servicio de Administración de Rentas, Honduras |
| Common management or control | In scope regardless of ownership | OECD |
| Exclusivity contracts and economic dependence | In scope regardless of ownership | OECD |
| Close family ties | In scope regardless of ownership | OECD |
| Residence in a listed tax haven | In scope regardless of ownership | OECD |
One exemption cuts the study obligation entirely. A taxpayer whose related parties are all inside Honduras, with none of them enjoying a special tax regime, does not have to prepare the study at all.
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Do I need a master file in Honduras?
No. Honduras has no master file requirement in force, so there is no threshold and no deadline to plan against. The May 2025 OECD country profile records that the SAR was about to approve an agreement requiring taxpayers to present a master file. No approving agreement has been located, so the threshold and the deadline are not confirmed.
Expect this to change. The same profile records that the SAR is working on new transfer pricing regulations, and a master file is the most likely near-term addition. A group that already prepares an OECD-style master file for other jurisdictions can reuse it the day Honduras switches the obligation on.
What goes in the Honduras local file?
A transfer pricing study, the estudio de precios de transferencia, with at least 14 listed elements in it. It is kept rather than filed, and goes to the SAR only when the SAR asks. There is no monetary threshold on it: having related-party transactions at all is the trigger.
The 14 elements run to the usual content of an OECD local file: the group structure, the Honduran entity's functions, assets and risks, a description of each controlled transaction, the method chosen for each one, and the benchmarking behind it. The USD 1,000,000 relief that exists in Honduras applies to Form 545, not to the study.
What language and currency does Honduras require?
Honduras sets no general transfer pricing language rule, and a foreign-language document can be translated by a Honduran consulate or by the Official Translator. In practice the SAR works in Spanish and the Form 545 platform is Spanish only, so a Spanish version is the safe default. Thresholds and penalties are set in US dollars and settled in lempira at the applicable exchange rate.
Does Honduras require country-by-country reporting?
Yes, at EUR 750 million of consolidated group revenue, measured in the national currency equivalent at the January 2015 exchange rate. The report is filed as an OECD-standard XML file within 12 months of the last day of the reportable fiscal year. The notification requirement for local constituent entities is not confirmed from a primary source, so this page does not state one.
The obligation exists because Honduras is a member of the OECD Inclusive Framework, which commits it to the country-by-country template, even though Honduras is not an OECD member. A group whose ultimate parent sits outside Honduras normally files the report in the parent's jurisdiction rather than here.
What is Form 545 and who files it?
Form 545 is the annual transfer pricing informative return, the Declaración Jurada Informativa Anual sobre Precios de Transferencia. Medium and large taxpayers with related-party transactions file it. Small taxpayers file it only once related-party transactions pass USD 1,000,000 in the period. The SAR publishes the format guidance[3] for it.
The USD 1,000,000 test counts accumulated related-party transactions, domestic and foreign together, converted at the Central Bank of Honduras exchange rate on 31 December. The small-taxpayer threshold was set by an agreement published in the official gazette[4] in 2016. The return goes through the SAR Oficina Virtual, the online filing office.
When is Honduras transfer pricing documentation due in 2026?
Form 545 is the only fixed-date filing, due 30 April 2026 for calendar-year taxpayers or the next business day if that falls on a weekend. A taxpayer on a special fiscal period files within three months of fiscal close. Everything else is either on request or tied to year end.
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| Obligation | Applies to | Deadline for 2026 | Source |
|---|---|---|---|
| Form 545 informative return | Medium and large taxpayers, and small above USD 1,000,000 | 30 April 2026, or the next business day | Servicio de Administración de Rentas, Honduras |
| Form 545, special fiscal period | Taxpayers not on a calendar year | Within three months of fiscal close | Servicio de Administración de Rentas, Honduras |
| Local transfer pricing study | Taxpayers with related-party transactions | On request, no fixed date | Servicio de Administración de Rentas, Honduras |
| Country-by-country report | Groups above EUR 750 million | 12 months after fiscal year end | Servicio de Administración de Rentas, Honduras |
| Master file | Not applicable | Not yet mandatory | OECD |
What are the penalties for getting Honduras transfer pricing wrong?
Fines are fixed in US dollars and settled in lempira, so the downside is quantifiable rather than open-ended. Failing to provide documentation, or providing false or incomplete documentation, costs USD 10,000. Understating the tax base adds a percentage of the adjustment on top.
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| Breach | Penalty | Source |
|---|---|---|
| Failing to provide documentation, or false or incomplete documentation | USD 10,000 | OECD |
| Understating the tax base | 15% of the adjustment | OECD |
| Understating the tax base together with the documentation breach | 30% of the adjustment or USD 20,000, whichever is greater | OECD |
| Any other breach of the transfer pricing law | USD 5,000 | OECD |
One trap catches groups that true up intercompany margins at year end. A downward corresponding adjustment in Honduras needs prior SAR approval. The Honduran entity cannot simply book a lower taxable base because the parent decided the margin was too high.
Does Honduras have safe harbours or advance pricing agreements?
No safe harbours, and no working advance pricing agreement programme. Advance pricing agreements are provided for in the transfer pricing law, but the SAR had no operating programme as of May 2025, so applying for one is not currently something you can do. The only relief in the regime is the USD 1,000,000 exemption from Form 545 for small taxpayers.
How do Honduras rules differ from the OECD baseline?
Honduras follows the OECD guidelines largely, and treats them as a technical reference where they are consistent with Honduran law. If you already run OECD-style documentation, four differences matter.
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| Difference from the OECD baseline | Honduras position | Source |
|---|---|---|
| Master file | Not yet mandatory, with an agreement in preparation | OECD |
| Local documentation | A study kept and produced on request, never filed | Servicio de Administración de Rentas, Honduras |
| Annual return | Form 545 sits at the centre of compliance, with no OECD equivalent | Servicio de Administración de Rentas, Honduras |
| Safe harbours and advance pricing agreements | No safe harbours, and no operating agreement programme | OECD |
The informative return is the characteristic Latin American feature, and the one to plan for first. It has a date on it, and the date does not move.
How we help with Honduras transfer pricing
Honduras asks for a filing on a fixed date and a study that has to exist before anyone asks for it. We prepare the study, build the benchmarking behind each controlled transaction, and file Form 545 before 30 April. See how our transfer pricing software works.
Book a demo for a review of your Honduras exposure before the next Form 545 deadline.
Official sources
4 sources
- 1.OECD. Transfer pricing country profile: Honduras (May 2025)
- 2.Servicio de Administración de Rentas, Honduras. Transfer pricing regulation law (Decree 232-2011)
- 3.Servicio de Administración de Rentas, Honduras. Form 545 annual transfer pricing return: format guidance (2025)
- 4.Secretaría de Finanzas, Honduras. Agreement DEI-SG-004-2016, small-taxpayer threshold (La Gaceta)
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.
