The Peru tax authority (SUNAT) has published Report No. 036-2021-SUNAT/7T0000, which provides guidance in relation to the application of Peru's transfer pricing rules. In particular, guidance is providing on the use of multi-year data in determining arm's length transfer pricing. In this respect, it provided that data from two or more years prior to or after an audit exercise may be used in determining whether or not transactions are comparable. Such multi-year data may not, however, be used in determining the arm's length price (profit margin) range for a transaction or adjustments. The guidance also provides that for the purpose...