Caribbean territory Aruba has released instructions on the completion of transfer pricing documentation and released model templates for completion.
In announcement no. 86 of 2019, the Government of Aruba confirmed the introduction of a transfer pricing documentation regime in line with that proposed by the OECD in BEPS Action 13. It is effective for fiscal years ending on or after January 1, 2019. The release includes examples of the master file, local file, and country-by-country report multinational groups should complete.
The CbC report should be filed annually and contain a breakdown of the amount of revenue, profits, taxes, and other indicators of economic activities for each tax jurisdiction in which the multinational group does business. Under the OECD framework, the CbC report should be filed by companies headquartered in Aruba whose consolidated group turnover exceeds EUR750m, or where a group has operations in Aruba but will file its report in a territory that lacks an agreement for the exchange of CbC reports with Aruba.
The Decree implementing Article
30, second paragraph, and Article 32, fifth paragraph, of the National Ordinance on Profit Tax (AB 1988 no. GT 47) (the Regulation on additional documentation requirements for transfer pricing) was published in the Official Gazette on December 23, 2019,