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Peru Clarifies Use of Most Appropriate Method in Intragroup Services Transfer Pricing Prior to 2019

24 March 2021

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Approved Changes

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Peru

The Peru tax authority (SUNAT) has published Report No. 135-2020-SUNAT/7T0000 concerning the use of the most appropriate method in intragroup services transfer pricing prior to amendments made by Legislative Decree No. 1369, which took effect 1 January 2019. In particular, SUNAT addresses a question of whether the provisions of the fourth paragraph of article 32-A(i) of the Income Tax Law, prior to its repeal by Legislative Decree No. 1369, prohibited the use of the most appropriate method to determine the market value of services other than low value-added services. Prior to its repeal, the fourth paragraph of article 32-A(i) established...