Transfer Pricing Services

In recent years, Peru has implemented several changes in its tax policy related to Transfer Pricing (TP). In effect, a series of Decrees and Resolutions were published with the objetive of aligning with international guidelines of TP, focused not only on local companies, but also on Multinational Enterprises (MNE) with a presence in Peru.
Consequently, companies must be concerned not only to validate whether operations carried out with related companies and/or non-cooperating territories or residents in countries with low or no taxation were carried out at market values (arm's length principle), but also that the agreed prices are related to the functions, assets and risks associated with the value chain. Additionally, they must have supporting documentation that shows the nature of these operations.
It should be noted that as of 2016, Peruvian companies are obliged, based on their income (individual and / or Group) and the amount of their intercompany operations, to submit three types of Informative tax Return (ITR): ITR- Local Report, ITR-Master File and ITR-Country by Country Report.

Our services are aimed to providing assistance in the correct and timely identification of the appropriate TP methodology and the preparation of the ITR- Local Report, ITR-Master File and ITR-Country by Country Report; as well as the support documentation regarding the determination of the transfer prices, which will allow you to reduce the risk of possible penalties by the Tax Administration.

As part of our services, below we detail the main products that we put at your disposal:

  • Preparation of the Informative Tax Return Reports, required by Peruvian Tax Administration: Regarding the ITR-Local Report, corresponds Annex I or Annexes II, III and IV. Additionally, the ITR-Master File and the ITR-Country by Country Report.
  • If your company receives services from related companies, we provide advice and preparation of the Benefit Test. 
  • Prospective Analysis of Transfer Pricing.
  • Advice in the presentation of the TP Informative Tax Return  - PDT 3560 (until 2015) and from the fiscal year 2016, the Virtual Forms ITR 3560, ITR 3561 and ITR 3562.
  • Support in the management of intercompany transactional documentation.

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