TRANSFER PRICING


Transfer Pricing rules allows to establish the market value of the transactions carried out between related parties; with residents in non-cooperating countries or territories, or with low to tax-free countries; and, transactions that are made with individuals whose income or savings, come from those transactions which are subjected to a preferential tax regime.

Taxpayers must comply with the transfer pricing regulations that include the submission of tax information returns to the National Superintendency of Tax Administration – SUNAT (Local File, Master File, and Country by Country Report), according to certain parameters.

+VALUE provides specialized and comprehensive advice on Transfer Pricing, based on our team’s complete knowledge of international requirements and Peruvian regulations.

Our extensive experience in the public and private sector provides a unique approach, allowing our clients to carry out their transactions safely, minimizing their tax risks.

Our advice in Transfer Pricing includes the following:

COMPLIANCE WITH FORMAL OBLIGATIONS

We offer support in the preparation, conformity with and / or second review of the formal obligations required by law, considering the needs of each client, pursuant to the Peruvian regulations:

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TRANSFER PRICES DIAGNOSTIC

We evaluate operations before the closing of the fiscal year or the Income Tax Return in order to verify that they have been carried out according to the applicable guidelines on Transfer Pricing rules. Or, in this case, identify problems in determining the market value, in order to take corrective measures.

Transfer Pricing Diagnostic contributes to solving potential Transfer Pricing problems, avoiding future observations by the Tax Authority. It also allows projecting a possible restructuring business supported by prior tax and economic planning.

TAX PLANNING

We advise in the planning of Transfer Pricing in order to generate fiscal efficiencies and reduce tax risks. Examples include the elaboration of intragroup service planning, financing policies, valuations of companies or intangibles from the tax perspective, supporting the business restructuring, among others.

Tax planning is a business management tool that enables efficient operational decision-making. It is comprised of the following phases:

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TAX AUDITS

We provide comprehensive advice and support in transfer pricing auditing proceedings, establishing the best strategy to prevent observations of the Tax Administration or minimize their impact.
To achieve an optimal result, the following phases are carried out:

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ADVANCE PRICING AGREEMENTS

We advise in choosing the most appropriate method for determining market value, as well as the analysis of the potential contingencies that the company could have in the execution of the Advance Pricing Agreement (APA), supporting it before, during and after the process. +VALUE understands that successful results of an APA relies upon a complete understanding of the Tax Administration requirements in relation to the information to be required and the subsequent verification mechanisms. We have the necessary tools and experience to reach a successful result.