Global

Details

  • Service: Tax, Global Transfer Pricing Services, Global Compliance Management Services
  • Type: Regulatory update
  • Date: 3/22/2013

Peru - Expanded thresholds for transfer pricing study 

March 22: Peru’s tax administration (SUNAT) proposed to modify the “formal” transfer pricing requirements, by requiring that the transfer pricing study also be filed annually along with the transfer pricing information return. Also, the income / monetary thresholds for taxpayers conducting transactions with entities in “tax haven” jurisdictions are expanded.

Currently, taxpayers must prepare and retain the transfer pricing study. There is no current requirement that the transfer pricing study also be provided / filed with the tax administration (unless specifically requested).


If the draft resolution is finalized (as proposed), the changes would apply for FY 2012. Thus, taxpayers would be required to prepare and retain the transfer pricing study, but also to submit the study along with the transfer pricing information return for FY 2012 (which must be filed in June 2013).


Read TaxNewsFlash-Transfer Pricing: Peru - Proposed changes to transfer pricing study, reporting requirements

Expansion of rules for transfer pricing study

Monetary thresholds that require otherwise “exempt taxpayers” from having to comply with the formal transfer pricing reporting requirements are expanded, to apply to transactions conducted with entities located in “tax haven” jurisdictions.


Thus, under these provisions, taxpayers are required to prepare a transfer pricing study if:


  • Annual net income is greater than PEN 6 million (approximately U.S. $2.3 million); and
  • The total amount of transactions between related parties and with entities located in tax haven jurisdictions is greater than PEN 1 million (approximately U.S. $400 million).


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


Sophia Castro Jurado

+51 (1) 611 3000


Juan Carlos Vidal

+51 (1) 611 3000 Ext. 3363




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