• Service: Tax, Global Transfer Pricing Services, Global Compliance Management Services, International Tax
  • Type: Regulatory update
  • Date: 5/31/2013

Peru - Changes to transfer pricing obligations 

May 31: Guidance published this week by the tax authority (SUNAT) introduces changes regarding the formal transfer pricing obligations and reporting requirements in Peru.

Among the new rules, it is now mandatory for taxpayers to provide an annual transfer pricing technical study.

Resolución de Superintendencia N° 175-2013-SUNAT (30 May 2013) sets forth the guidance concerning the updated transfer pricing reporting requirements in Peru.

  • The rules now require that a transfer pricing technical study must be presented to the SUNAT (the tax authority) each year, together with the transfer pricing affidavit. The study for 2012 is due in October 2013.
  • The guidance extends the due date for complying with the transfer pricing requirements for the tax year 2012 to October 2013.
  • A new version of the transfer pricing form will be made available 1 June 2013, and is expected to require more information.
  • Transactions with entities located in “tax haven” jurisdictions (which previously were automatically required to be reported in the transfer pricing affidavit, regardless of the amount of the transaction) must also be included in the calculation for materiality, in order to assess whether there must be compliance with the formal transfer pricing reporting requirements.

Read the guidance (Spanish) [PDF 421 KB]

KPMG observation

Multinational entities with operations in Peru immediately need to analyze and consider the effects of this week’s SUNAT guidance because it introduces important changes regarding taxpayers’ formal transfer pricing obligations.

For more information, contact a tax professional with KPMG’s Global Transfer Pricing Services practice:

Juan Carlos Vidal

+51 (1) 611 3000 Ext. 3363

Contact a tax professional with KPMG's Global Transfer Pricing Services.

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