Peru: Transfer pricing documentation | KPMG Global
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Peru: Transfer pricing documentation—country-by-country reporting, Master file, Local file

Peru: Transfer pricing documentation

Amendments made to Peru’s tax regulations update the documentation requirements for transfer pricing purposes, and include country-by-country (CbC) reporting, Master file, and Local file obligations.


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The changes to the regulations, published 17 November 2017, include:

  • A definition of entities or persons required to file CbC reports
  • Details of the minimum information to be recorded in the Local file, such as the identity of personnel on whom the taxpayer company's management and administration depend; information about intra-group services (benefit test and low value-added activities), and work papers that connect the company's financial information with its transfer pricing analysis
  • Details of the minimum information to be recorded in the Master file and CbC report (generally aligned with the OECD standards)
  • The effective date for the application of these recordkeeping requirements

The dates for filing required forms are still pending, and a regulation related to exports or imports of commodities and intra-group services is still pending.


Read a November 2017 report [PDF 324 KB] prepared by the KPMG member firm in Peru

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