The assistance of a firm with subject matter experts, such as TGS Sarrio & Asociados, is key to guarantee a solid tax strategy.

Companies that conduct businesses with related or resident companies in tax havens must present the Transfer Price Study to the tax authority (SUNAT) this June and sustain the nature of their relevant transactions.  Such Study must comprise the necessary economic and legal support in order to prove that transactions are being agreed at market value.

Our team of experts will assist you in:

  • The making of Technical Transfer Price Studies
  • The making of the Informative Transfer Price Affidavit
  • The collection of the documentation and information defined in the Income Tax Regulations.
  • An assessment of the price or margin of competence for your transactions, that are subject to analysis.
  • Advice on inspections or tax litigations related to compliance with transfer pricing rules.
  • Advice on the negotiation, execution and implementation of Advance Pricing Agreements (APAs).
  • Value chain tax planning and transfer pricing tax planning
  • Analysis of potential expenses for cessation of operations, risks related to the incorporation of permanent establishments and the preservation of tax benefits as a result of the movement of functions, assets and risks    

Informative Affidavit Local Report

Two tranches have been established in order to determine the information to be filed with the SUNAT.  Such information is linked to the amount of transactions made with related parties and/or from, to or through low or null taxation territories:



Total amount of transactions with related parties and/or tax havens

Tranch Report


100 Applicable Tax Units (UIT) ≤ Transactions < 400 Applicable Tax Units (UIT)

Tranch I

Appendix I

400 Applicable Tax Units (UIT) Transactions

Tranch II

Appendix II, Appendix III and Appendix IV

Without prejudice to the formal obligations shared, it is important that companies be aware of the market values operations between related-parties before the expiration of the Annual Income Tax Declaration for the year (end of March or early April of the following year) and hence, avoid subsequent adjustments that would affect its assessment.  If you decide to hire our professional services, we commit to assisting you in the preparation of the Informative Affidavit Local Report where the amount and nature of the transactions, functional analysis and the application of transfer pricing methodologies will be shown. 

Informative Affidavit Master Report

All taxpayers who belong to an Economic Group (National or Multinational), whose Parent Company consolidates financial statements or is required to do so in accordance with IFRS 10, are obliged to file the Informative Affidavit Master Report. 
Likewise, according to the resolution mentioned above, the following parameters must be met:



Taxpayer Accrued Income

Total amount of transactions with related parties and/or tax havens

Revenue > 20,000 Applicable Tax Units (UIT)

400 ITU Transactions

Informative Affidavit Country-by-Country Report

All taxpayers, who belong to a Multinational Economic Group whose accrued income in the previous taxable year are equal or greater than S/ 2’700’000,000 o € 750’000,000 as such declaration corresponds (according to the consolidated financial statements to be made by the multinational group’s parent company), are required to file the Informative Affidavit Country-by-Country Report.

Moreover, the following conditions must be also met:

  1. Whenever the taxpayer is the multinational group’s parent company.
  2. Whenever, as paragraph (1) letter b in Article 116°of the Income Tax Law Regulations (LIR) states, the non-domiciled parent company of the multinational group is not required to file the CBCR in its domicile jurisdiction or residence.
  3. Whenever, according to paragraph (2) letter b in Article 116°of the Income Tax Law Regulations (LIR), the domicile jurisdiction or the parent company’s residence does not have an agreement in force with Peru between competent authorities for exchange purposes of the CBCR on the expiration date for the tax return filing deadline.
  4. Whenever, as paragraph (3) letter b in Article 116°of the Income Tax Law Regulations (LIR) states, there is a systematic non-compliance with the exchange of tax information regarding an international treaty or decision of the Andean Community Commission that has been informed by SUNAT to the taxpayer domiciled in the country.
  5. Whenever, in accordance with paragraph 4 in Article 116° letter (b) of the Income Tax Law Regulations (LIR) or as the fourth paragraph letter (b) of the same article provides, the taxpayer domiciled in the country inform SUNAT that they have been designated by the multinational group as a parent-company representative or responsible for filing the CBCR.  
  6. Whenever the domiciled taxpayer is designated by SUNAT as responsible for filing the CBCR in accordance with the fifth paragraph of Article 116° letter (b) of the Income Tax Law Regulations (LIR).


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