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.
In general, the regulation (Spanish) provides the following:
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.
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).
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 | firstname.lastname@example.org
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