Regulations with respect to the amendments introduced to the Income Tax Law in July 2012 were issued by means of Supreme Decree No. 258-2012-EF published on 18 December 2012. The regulations dealt with transfer pricing methods, APAs, CFC rules, tax havens and R&D expenses. For the main amendments concerning tax havens and R&D expenses. The main amendments concerning transfer pricing, APAs and CFC rules are as follows: -   New transfer pricing provisions state that in the cases of cyclical businesses the determination of transfer prices made by the tax administration may be based on information and comparable transactions from...