Transfer Pricing Updates in Peru

Peruvian tax authorities (SUNAT) issued Transfer Pricing Resolution N° 163-2018/SUNAT, published in the official gazette “El Peruano” on June 29, establishing the rules for submitting Master File and Country by Country Reports



Who is required to submit a Master File?

Taxpayers that are members of a group will be required to submit a Master File if:

  • The taxpayer’s annual revenues in the fiscal year exceed 20,000 Tax Units (approximately  $24M USD), and;
  • The taxpayer has carried out transactions with related parties or tax havens for a total amount that is greater than or equal to 400 Tax Units (approximately $500,000 USD).


General considerations


  • The document must be prepared and presented in a PDF file, in an unprotected format, that allows reading, copying and printing of the information.
  • Regardless of whether the document contains tables or graphics, it cannot be submitted in image format.
  • The Master File must be prepared and submitted in Spanish.



The Master File should contain, among other information, the organizational structure of the group, as well as the description of the business activities of its members, the group’s policy regarding intangibles, the group’s financial operations, and the financial and fiscal position of group members.




Who is required to submit a CbCR?


Provided that the revenue accrued by the whole multinational group, in the fiscal year before the reporting fiscal year, is greater than or equal to PEN 2.7 billion (approximately $826M USD), the following entities are legally required to submit the CbCR


  1. The parent entity of the multinational group if it is based in Peru;
  2. The taxpayer that is a member of the multinational group when:
    • It has been appointed by the group as the surrogate parent entity
    • The ultimate parent entity of the group is not required to file the CbCR in its country of residence
    • The CbCR is submitted to the country of residence of the ultimate parent entity, but Peru has not established procedures for the automatic exchange of CbCR with that jurisdiction
    • The ultimate parent entity has submitted the CbCR, and even though Peru has an information exchange mechanism with that jurisdiction, there has been systematic failure to exchange information, according to SUNAT


The resident entity of the multinational group shall notify SUNAT whether it is the parent entity or the surrogate parent entity, no later than the last business day of the month previous to the due date for submitting the informative return.  If at that date this requirement has not been complied with, all resident taxpayers members of the multinational group will be considered as reporting entity.


The taxpayer is exempt from submitting the informative return if, at the due date, the multinational group fulfills said declaration through a surrogate parent entity with residence in another jurisdiction.  For this purpose, the taxpayer must inform SUNAT of the designation of the surrogate parent company in a written form, attaching in turn, the communication presented by the surrogate entity in its jurisdiction.



The Country by Country Reporting should contain information related to the amount of income, losses or profits, income tax paid and accrued, declared capital, undistributed results, number of employees, and tangible assets other than cash, concerning each jurisdiction in which the multinational group operates. Also, the identification of each member of the multinational group is required, indicating the jurisdiction of the domicile of each of them, as well as the nature of their main economic activities.


Means and form to present the informative returns


A virtual platform will be used to file the Master File Information Return (Virtual Form No. 3561) and Country by Country Reporting Informative Return (Virtual Form No. 3562).  This platform will be available through the Peruvian tax authority (SUNAT) website.


Deadline for submission


The deadline schedule to submit the Master File and Country by Country Reporting informative returns is the same as the one approved for the submission and payment of monthly taxes due in October (tax period September) of the following fiscal year.


Deadline for FY 2017 informative returns

Taxpayers required to fulfill the informative returns for FY 2017 must keep to the following deadline schedule:


0 November 15, 2018
1 November 16, 2018
2 and 3 November 19, 2018
4 and 5 November 20, 2018
6 and 7 November 21, 2018
8 and 9 November 22, 2018
Good taxpayers November 23, 2018




For additional information, please do not hesitate to contact us:


BaseFirma Lima

Jimena Caldas Ugaz

250 Del Ejercito Ave., Ste. 208

Miraflores, Lima

Phone number: +511 717 7248,

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