You are Marisol Andino, chief financial officer of Grupo Comercial del Norte in Tegucigalpa. Honduras's tax authority has just opened an audit of a single number: the price at which your plant sells its components to the group's sister company in Panama. By Monday 13 October 2025 you must put in writing which price you defend, and with which method.
The situation
The group, 82% controlled by the Bardales family, bills about US$320 million across four countries. Its Honduran plant makes plastic components for about US$35 a unit and sells them at US$45 to Comercial de Panamá, which resells them to foreign customers at US$55 to US$65. In Honduras profits pay close to 30% tax; the Panamanian company's export earnings are barely taxed.
The authority, known as the SAR, compares markups on cost: Central American manufacturers earn 35% to 40%, and traders 8% to 12%. Your plant earns 28.6%; Panama, between 22% and 44% depending on the customer. The plant has US$33 million of assets and a three-year contract that guarantees its demand; Panama has the office, the sales team, the customers and the risk of not being paid.
Nobody ever documented how the US$45 was set; the price predates your time in the job. And there is a 2021 email from the general manager of the time: "Let's take advantage of Panama's low taxes to move profits there." The SAR says it will send it to prosecutors. Your dashboard shows US$7.5 million of tax exposure, US$38 million of cash, documentation compliance at 15% and criminal risk at 85%.
Don Ernesto Bardales, the chairman, wants to defend a price "set in good faith." Rodrigo Valladares, the tax lawyer, reminds you that any figure you hand the SAR will end up in the prosecutor's file. Lourdes Erazo, the treasurer, reminds you that all of it comes out of the same cash.