Transfer Pricing obligations in Peru are now being regulated in
more detail than ever before. This could mean that intra-group
operations will be subjected to greater scrutiny by the Peruvian
tax authorities.
The changes cover the filing of the Local Report, the Master
Report, and the Country-by-Country Report, with effect from 2016,
and include dates by when the amendments must be applied.
For the Local File, the amendments are applicable from the year
2017 (corresponding to 2016 operations); for the Master File and
Country-by-Country File, the amendments are applicable from 2018,
corresponding to 2017 operations.
The changes include more detail required for all files,
including the minimum information required. For the Local File,
this information includes identifying the personnel on whom the
company's management and administration depend, plus
information about intra-group services (benefit test and low
value-added activities), and work papers that enable
