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July 13, 2026

SECTION 8 - TAX AVOIDANCE

Chapter 2 - Indirect Transfer of Profits between Related Entities

Article 57

A resident entity linked to others must submit both a master file and a local file in the format established by the OECD, unless the Authority adopts its own forms. The submission is to be made within the timeframe specified for returns or within any other timeframe set by the Authority. This obligation applies under the following conditions: