Legal Bulletin


The Tax Administration will have broader terms to exercise its audit powers over taxpayers.

The Government proposed to extend the statute of limitation from two (2) years to three (3) years, computed since:

  • The due date to file the tax return;
  • The filing date of the tax return, when it was filed extemporaneously;
  • The date of the request for a balance in favor; and
  • The use of the balance in favor in subsequent tax periods.  

In the same way, the Government proposes to extend the statute of limitation of the tax returns that report NOL from five (5) years to eight (8) years since the submission date.

If the tax losses are offset during the last two (2) years before the due date, the statute of limitation would be extended for three (3) more years in regards to the corresponding tax return.

For taxpayers obliged to file transfer pricing returns, the statute of limitation will be six (6) years since the due date, or the submission date, in the cases in which it was submitted extemporaneously.