We support our clients in complying with Transfer Pricing legislation, which is why we handle all phases involved in the preparation of the Local Report, Master Report, and Country-by-Country Report. Additionally, we provide comprehensive advisory services to support the benefit test, Transfer Pricing planning, and advisory services during audits in this area.
Our Services
Taxpayers who meet the following criteria during the taxable year to which the declaration corresponds are required to submit the mentioned report:
- i) Earn accrued income greater than 2300 UIT; and,
- ii) Carry out transactions within the scope of application, whose total amount is equal to or greater than 100 UIT (Annex I) and 400 UIT (Annex II, III and IV)
We prepare the Local Report in accordance with local regulatory requirements and transfer pricing practices to ensure that the operations comply with the arm's length principle.
Taxpayers who are part of a Group and meet the following criteria during the taxable year to which the declaration corresponds are required to submit the mentioned report:
- iii) Earn income greater than 20,000 UIT; and,
- iv) Carry out transactions with related parties and/or tax havens, the total amount of which is equal to or greater than 400 UIT.
We prepare the Master Report, taking into consideration the local regulatory requirements and transfer pricing practices in accordance with the guidelines of the Organization for Economic Co-operation and Development (OECD).
Taxpayers are required to submit this report if they earn accrued income equal to or greater than S/ 2.7 billion, according to the consolidated financial statements that the Multinational Group's parent company must prepare.
We provide support in the preparation of the Country-by-Country Report, considering the local regulatory requirements and transfer pricing practices in accordance with the guidelines of the Organisation for Economic Co-operation and Development (OECD), as well as advisory services for submitting the report to the Tax Authority.
We are committed to supporting our clients with comprehensive advisory services that substantiate the benefit test and the authenticity of intra-group services, with the goal of justifying the deductibility of costs and/or expenses. The mentioned test must include the following key sections:
- Review of the intra-group services received.
- a) Actual provision of the service.
- b) Tangible benefit from receiving the service.
- c) Shareholder-related activities
- Review of the non-duplicity of intra-group services received.
- Characterization of intragroup services.
- Review of the segmented financial information of the intra-group service provider.
We provide comprehensive advisory services for the Informative Affidavit of the Final Beneficiary in accordance with Legislative Decree No. 1372, regulated by Supreme Decree 003-2019, and implemented through Resolution No. 185-2019/SUNAT. As a result, legal entities and/or legal arrangements domiciled in Peru are required to submit an Informative Affidavit identifying their final beneficiaries.
We offer a comprehensive service that includes diagnosis, defense strategy, and support during audit processes, ensuring our clients receive appropriate advice when facing audits or requests from the Tax Administration regarding transfer pricing matters.
