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Peru Implements New Transfer Pricing Documentation Requirements and Rules on Intragroup Services

11 January 2017

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Approved Changes

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Peru

Peru has published Legislative Decree No. 1312, which implements a number of new transfer pricing documentation requirements and rules based on the OECD BEPS project. The main aspects of the decree include: A Local Report (file) requirement for taxpayers whose accrued income in the taxable year exceeded 2,300 tax units (UIT) (~USD 2.75 million), which must be submitted annually with respect to transactions that generate income and/or deductible costs or expenses for tax purposes (tax authority may also require with respect to transactions that generate exempt income and/or non-deductible costs or expenses); A Master Report (file) requirement for taxpayers who...