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Peru Publishes Decrees on Intragroup Services, Thin Capitalization, Indirect Transfer Rules, Accrual of Income, and Non-Cooperative Jurisdictions

10 January 2019

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Approved Changes

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Peru

Peru published a series of Supreme Decrees in the 30 December 2018 edition of the Official Gazette, including rules in relation to intragroup services, thin capitalization and indirect transfer rules, accrual of income, and non-cooperative jurisdictions and preferential regimes. Each Decree generally applies from 1 January 2019 Intragroup Services Supreme Decree No. 337-2018-EF includes provisions in relation to Peru's rules on intragroup services, which include a benefits test and related documentation requirements for the purpose of deducting costs/expenses related to such services. With respect to the benefits test, the Decree provides that a service is considered to provide economic or...