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Peru: Country-by-country reports, transfer pricing documentation due in November 2018

Peru: Country-by-country reports due in November 2018

In Peru, regulation No. 163-2018 concerning the rules for filing transfer pricing documentation—specifically, Master files and country-by-country (CbC) reports—has been published.


Related content

In general, the regulation (Spanish) provides the following:

  • The deadline for filing the information returns relating to the Master file and to the CbC report that corresponds to FY 2017 is a date in November 2018 (the exact due date depends on the tax ID number of the taxpayer company).
  • Both information returns for the Master file and CbC report must be filed electronically via the tax administration’s website. 
  • The Master file must be provided in Spanish and filed as a PDF. 

While the content of the information returns for the Master file and CbC report is similar to the standard provided under the OECD’s base erosion and profit shifting (BEPS) Action 13, there are some specific local requirements regarding the form and content of the files to be presented. Accordingly, the Master file and CbC reports must be customized to match the requirements in Peru.

Threshold amounts

The Master file information return is mandatory for Peruvian entities with revenues (that is, separate entity revenues) greater than 20,000 Local Tax Units (approximately U.S. $ 24 million) and having intercompany transactions, the sum of which is greater than 400 Local Tax Units (approximately U.S. $ 490,000).

MNE groups

The CbC report for FY 2017 must be filed in Peru, and taking into account that Peru has not signed CbC information exchange agreements with other jurisdictions, the requirement for filing the CbC report applies for all entities operating in Peru if part of a multinational entity (MNE) group.

Before filing the CbC report, it may be necessary to file a prior notification with the tax authorities depending on the structure of the MNE group and its presence in Peru.


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

Juan Carlos Vidal | +51 (1) 611 3000 Ext. 1045 |

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