What transfer-pricing obligations does a Guatemalan subsidiary have with its foreign parent?

Decree 10-2012, Book I, Chapter VI ('Special Valuation Rules between Related Parties'), sets out the arm's-length principle in Article 54. It applies to transactions between a Guatemalan resident and a related party resident abroad that affect the taxable base for the period. Obligations: (i) a Transfer Pricing Study (Article 65 of the Regulations), available on request from the tax authority (SAT), and (ii) the related-party Annex to the Annual Income Tax Return, filed through the SAT online portal (Agencia Virtual).