On 28 November 2025, the Honduran Tax Authorities (Servicio de Administración de Rentas or SAR) published a "Guide on Country-by-Country Reporting (CbCR) Frequently Asked Questions" (the Guide). The Guide contains information on frequently asked questions and procedures for submitting the Country-by-Country (CbC) Report and notification.

Background

In March 2024, Regulation SAR-653-2023 was published regarding the introduction and implementation of the CbC Report (and its notification) for taxpayers residing in Honduras who are part of a Multinational Group. This obligation is consistent with Action 13 of the Base Erosion and Profit Shifting (BEPS) Project of the Organisation for Economic Co-operation and Development (OECD). (For background, see EY Global Tax Alert, Honduran Tax Authority issues Agreement on CbCR, dated 25 April 2024.)

Regulation SAR-653-2023 takes effect for reportable Fiscal Years of Multinational Groups starting from 1 January 2025.

Obligated parties

The provisions established in the Regulation SAR-653-2023 apply to taxpayers that are tax-resident in Honduras, as well as to the Ultimate Parent Entity or designated Constituent Entity of a Multinational Group with consolidated revenues are equal to or greater than €750m in national currency, according to the exchange rate in effect as of January 2015.

Important aspects of the Guide

Information on submitting the CbC Report notification

The deadline for submitting the notification for fiscal year 2025 is 31 December 2025. The notification must be submitted exclusively through the Tax Authorities' website (Oficina Virtual or OVI) using a form that is available in the section called "Country-by-Country Report."

Note that paper notifications sent to the Tax Authorities' offices will not be accepted.

The notification must include (1) confirmation that the reporting entity is part of a Multinational Group, (2) the reportable fiscal year, (3) confirmation that the taxpayer is the Ultimate Parent Company or surrogate entity and (4) the reporting entity's data, including legal name, trade name, tax residence and Tax ID.

If the Multinational Group has several subsidiaries in Honduras, notifications must be made individually for each entity.

Information on submitting the CbC Report

The Guide provides general information related to the submission of the CbC Report, as well as answers to relevant questions such as:

• What is the CbC Report?
• What is the purpose of the CbC Report?
• Where does the obligation originate?
• With which countries is information shared?
• What should the CbC Report include?

The reportable fiscal years of Multinational Groups are those beginning as of 1 January 2025 and onward. The deadline for submitting the CbC Report is a maximum of 12 months after the last day of the Multinational Group's reportable fiscal year.

If a Honduran entity notifies the Tax Authorities that its Multinational Group will submit the CbC Report in Honduras, the Tax Authorities will enable or provide the Multinational Group with the corresponding templates for submitting the CbC Report.

The CbC Report must be submitted via an XML file that complies with the structure established by the OECD.

Implications

Affected entities should prepare for compliance with the CbCR requirements by reviewing their reporting structures, ensuring timely notifications and gathering necessary data to meet the upcoming deadlines.

In accordance with the provisions of the Regulation SAR-653-2023, section seven, failure in the submission of the notification or the CbC Report entails the following penalties:

• Failure to submit the CbC Report notification will be penalized in accordance with Article 160 of the Tax Code, as it constitutes a violation of Paragraph 10 of Article 63 of said Code.
• Late submission of the CbC Report notification will be penalized in accordance with Article 160 of the Tax Code.
• Failure to submit the CbC Report, or submitting it with false, manifestly incomplete or inaccurate data, will result in the penalty established in paragraph 1) of Article 19 of the Honduran Transfer Pricing Regulation (Ley de Regulación de Precios de Transferencia) for noncompliance with the provisions of paragraph 1) of Article 18 of the same Law.
• Late submission of the CbC Report will result in the penalty established in paragraph 1) of Article 19 of the Honduran Transfer Pricing Regulation, for noncompliance with the provisions of paragraph 1) of Article 18.