The government of Peru has announced the approval of Legislative Decree No. 1662 of 24 September 2024, which amends the Advance Pricing Agreement (APA) provision of the income tax law to allow the retroactive application (roll-back) of APAs in certain cases. In general, the roll-back of an APA is allowed when it is verified that the relevant facts and circumstances of previous years are the same as in the years covered by the APA and the ability of the tax authority (SUNAT) to determine income tax liability based on the application of the transfer pricing rules has not expired due...