In this edition, we present a summary of three crucial topics related to Transfer Pricing regulations. Stay up to date with the latest updates and how they may impact your company:
- Tax Administration Notifications
The Tax Administration has intensified its Transfer Pricing audit campaigns for the 2019-2023 fiscal years. This includes requests for local reports, Benefit Tests, and Master Reports. It is essential that companies comply with these obligations to avoid penalties and fines. - Application of New Transfer Pricing Methods
With the issuance of Legislative Decree No. 1663, new valuation methods have been introduced, such as discounted cash flow and multiples, which will allow for a more accurate analysis of transactions. These methods are applicable when traditional methods do not adequately reflect the economic reality of the transactions. - Clarifications on the Scope of the Benefits Test
Recent reports from SUNAT have clarified that lease agreements and trademark licenses between related parties do not require the application of the Benefits Test. This interpretation is key to avoiding potential errors in reporting.