The consumption sector grouped, for the practical purposes of this article, by the activities of commerce, hotels, bars, restaurants, transportation and storage, are those with the greatest recovery in the Gross Domestic Product based on the statistics published by the Central Bank of Dominican Republic, for the period from January to September 2021 and which reveal increases of 11.1%, 31.8%, 13.7% compared to the same period in 2020.
This result is aligned, on the one hand, with the global statistics of the sector according toOxford Economics, and that, in which case they present an average growth of 5.9% for the projection at the end of 2021; and on the other, with the progress made in the vaccination plan that, in one way or another, has increased consumer confidence.
However, the fact that the sector presents encouraging recovery results does not mean that the stage of generalized challenges and problems is not present in its businesses or day-to-day operations. It is extraordinarily evident that the changes in business models since 2020 are still continuing, and that, without a doubt, they adapt to the tastes and realities of the consumer, this being a true reflection of the evolution in our consumption habits and trends that went from being face-to-face to digital, and that will probably end in a hybrid model between the two previous ones.
Delays and global problems in logistics and transport are also part of the challenges currently facing the sector, and where the fact that much of the consumption is oriented to the “availability of today” and with immediate access stands out. In addition to the above, all those participants in this sector who belong to a multinational group with which they have a transaction subject to the evaluation and documentation of transfer prices, are also exposed to the need to revisit, once again, the policies intercompany established, emphasizing the revaluation of the same with respect to the current panorama, already narrated and remembering that precisely the economic and market conditions is one of the comparability variables required in any analysis of this nature.
In this regard, we highlight the need to validate the exposure and description of updated business information, especially how they operate, how they generate profit and what they are exposed, as well as the reasonableness of the methodological approach that in many cases points to the analysis of the generality without taking into consideration the challenges described, all this without neglecting the meticulous review in conjunction with the consultants of the validity of the comparable references used.
In general, it should be noted that the Transfer Pricing documentation should not represent a straitjacket or be tied to the premise of consistency, but rather, it should evolve along with the business and the market, obviously taking into consideration the requirements and other mandatory premises established both in the Dominican Tax Code and in its regulations.
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