Countries › Peru › Guide › 6. Taxes › Transfer pricing in Peru: scope, methods, the Local, Master and Country by Country reports, advance pricing agreements and longer dispute deadlines

Transfer pricing in Peru: scope, methods, the Local, Master and Country by Country reports, advance pricing agreements and longer dispute deadlines

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Last verified: 2026-10-28 · Status: Stable

Transactions with related parties, and with anyone in a low or no tax jurisdiction, must be priced at market value under one of six methods, interpreted in line with the OECD guidelines. Taxpayers with revenue above 2,300 UIT (S/ 12,650,000 in 2026) file an annual Local Report, members of groups with revenue above 20,000 UIT (S/ 110,000,000) a Master Report, and multinational group members a Country by Country Report. Commodity exporters and importers must report the pricing date before shipment, intragroup services must pass a benefit test, and transfer pricing assessments get longer deadlines for SUNAT and the Tax Court.

USD figures use S/ 3.452 per US dollar, the banking system selling rate published by the Superintendencia de Banca, Seguros y AFP for 27 October 2026, from the Banco Central de Reserva del Perú statistics series PD04640PD. UIT based amounts use the 2026 UIT of S/ 5,500 set by Decreto Supremo Nº 301-2025-EF. Conversions are for orientation only.

Key facts

Local Report revenue threshold	2300 UITLIR art. 32-A g) (DL 1312), as of 2026-10-28 · in force
Master Report group revenue threshold	20000 UITLIR art. 32-A g) (DL 1312), as of 2026-10-28 · in force
Specified transfer pricing methods	6 methodsLIR art. 32-A e), as of 2026-10-28 · in force
Minimum stake sold for discounted cash flow valuation	5 %LIR art. 32-A e) 7.2 c) (DL 1663), as of 2026-10-28 · in force
Deadline to appeal a transfer pricing assessment	30 business daysCódigo Tributario art. 146, as of 2026-10-28 · in force
Minimum retention of transfer pricing documentation	5 yearsLIR art. 32-A g), as of 2026-10-28 · in force

The rule

1. The transfer pricing rules apply to transactions with related parties and to transactions made from, to or through low or no tax countries or territories. SUNAT may adjust the agreed value only when it results in less Peruvian tax than market value would, or when the adjustment increases Peruvian tax on transactions with other related parties. An adjustment also applies to the counterparty, and a corresponding downward adjustment is allowed when a treaty partner's authority adjusts a related resident's prices and SUNAT accepts it.Texto Único Ordenado de la Ley del Impuesto a la Renta (Decreto Supremo Nº 179-2004-EF), as amended by Decreto Legislativo Nº 1381, Decreto Legislativo Nº 1112 and Decreto Legislativo Nº 1124, Art. 32-A letters a) and c), 2018-08-24 official text · verified 2026-10-28

2. Parties are related when one participates directly or indirectly in the management, control or capital of the other, or the same person or group participates in several entities; using an intermediary to disguise a related transaction also creates relation. The Reglamento lists the specific cases.Texto Único Ordenado de la Ley del Impuesto a la Renta (Decreto Supremo Nº 179-2004-EF), Art. 32-A letter b), 2003-12-23 official text · verified 2026-10-28

3. Six methods are available, choosing the most appropriate: comparable uncontrolled price, resale price, cost plus, profit split, residual profit split and transactional net margin. For exports and imports of goods with a known market quotation, the quotation applies on the pricing date the taxpayer reports to SUNAT; the report must be filed by the start of shipment or unloading, and if it is missing, late or inconsistent SUNAT uses the end of shipment (exports) or unloading (imports).Texto Único Ordenado de la Ley del Impuesto a la Renta (Decreto Supremo Nº 179-2004-EF), numeral 1 amended by Decreto Legislativo Nº 1381 and the third paragraph by Decreto Legislativo Nº 1537, Art. 32-A letter e) numerals 1 to 6 and third paragraph, 2022-03-26 official text · verified 2026-10-28

4. Other methods may be used when the six do not fit. For unlisted shares these include discounted cash flow; for other transactions discounted cash flow, multiples, equity value, appraisal and the multi period excess earnings method. Discounted cash flow cannot be used when the seller holds less than 5 percent of the company sold or the issuer's prior year net revenue does not exceed 1,700 UIT. A technical report supporting the value must be available when SUNAT asks for it.Texto Único Ordenado de la Ley del Impuesto a la Renta (Decreto Supremo Nº 179-2004-EF), numeral 7 as amended by Decreto Legislativo Nº 1663, Art. 32-A letter e) numeral 7, 2024-09-24 official text · verified 2026-10-28 · changed: Decreto Legislativo Nº 1663 (24 September 2024) rewrote the other methods rules for share and asset valuations from 1 January 2025.

5. Taxpayers with accrued revenue above 2,300 UIT must file an annual Local Report on transactions that generate taxable income or deductible costs. Members of a group with revenue above 20,000 UIT must file a Master Report (structure, business, intangible and financing policies), and members of a multinational group a Country by Country Report under the Reglamento. Supporting documentation must be kept, translated into Spanish, for five years or the limitation period, whichever is longer.
Cost to do it: Local Report applies above S/ 12,650,000 of revenue (about US$3,664,542); Master Report for groups above S/ 110,000,000 (about US$31,865,585). Preparation is usually outsourced to advisers.Texto Único Ordenado de la Ley del Impuesto a la Renta (Decreto Supremo Nº 179-2004-EF), letter g) as amended by Decreto Legislativo Nº 1312, Art. 32-A letter g), 2016-12-31 official text · verified 2026-10-28

6. SUNAT may sign advance pricing agreements with domiciled taxpayers. From 2025 it may also sign them with treaty partners' authorities through the mutual agreement procedure, and those bilateral agreements may cover earlier open years if facts are the same and no assessment has been notified.Texto Único Ordenado de la Ley del Impuesto a la Renta (Decreto Supremo Nº 179-2004-EF), letter f) as amended by Decreto Legislativo Nº 1662, Art. 32-A letter f), 2024-09-24 official text · verified 2026-10-28 · changed: Decreto Legislativo Nº 1662 (24 September 2024) added bilateral advance pricing agreements with rollback from 1 January 2025.

7. The OECD Transfer Pricing Guidelines are the interpretive source to the extent they do not contradict Peruvian law. For intragroup services, the taxpayer must pass a benefit test and provide the documentation requested as a condition for deducting the cost.Texto Único Ordenado de la Ley del Impuesto a la Renta (Decreto Supremo Nº 179-2004-EF), letter i) as amended by Decreto Legislativo Nº 1369, Art. 32-A letters h) and i), 2018-08-02 official text · verified 2026-10-28

8. Transfer pricing assessments have longer procedural deadlines: the one year audit time limit does not apply to transfer pricing audits; a late claim needs a bank guarantee for 12 months instead of 9; SUNAT has 12 months instead of 9 to decide the claim; the appeal deadline is 30 business days instead of 15; and the Tax Court has 18 months instead of 12.Texto Único Ordenado del Código Tributario (Decreto Supremo Nº 133-2013-EF), art. 62-A as amended by Decreto Legislativo Nº 1422 and art. 146 as amended by Decreto Legislativo Nº 1528, Art. 62-A numeral 3, art. 137 numeral 3, art. 142, art. 146 and art. 150, 2022-03-03 official text · verified 2026-10-28

Obligation	Who	Threshold	Rule
Local Report	Taxpayers with related party or low tax jurisdiction transactions	Revenue above 2,300 UIT (S/ 12,650,000)	LIR art. 32-A g)
Master Report	Members of a group	Group revenue above 20,000 UIT (S/ 110,000,000)	LIR art. 32-A g)
Country by Country Report	Members of a multinational group	Per the Reglamento	LIR art. 32-A g)
Commodity pricing communication	Exporters and importers of quoted goods	Every shipment, before it starts	LIR art. 32-A e)
Claim against an assessment	Taxpayer	SUNAT decides in 12 months	Código Tributario art. 142
Appeal to the Tax Court	Taxpayer	30 business days to appeal; 18 months to decide	Código Tributario art. 146 and 150

Transfer pricing filings and deadlines in Peru (UIT S/ 5,500 for 2026)

Worked example

A Peruvian distributor with 2026 revenue of S/ 40,000,000 (US$11,587,486) buys all its stock from a related company in Chile. Its revenue is above 2,300 UIT, so it files a Local Report for 2026 and keeps the supporting study for at least five years.
If its group's worldwide revenue exceeds 20,000 UIT (S/ 110,000,000), it also files the Master Report, and as part of a multinational group, the Country by Country Report under the Reglamento.
If SUNAT finds that a transactional net margin analysis supports a lower purchase price, it adjusts the cost upward in Peruvian income, and the company has 30 business days to appeal to the Tax Court after SUNAT decides its claim.

Step by step

Map related parties and any counterparties in low or no tax jurisdictions, including those reached through intermediaries.
Pick and document the most appropriate method for each transaction type, with comparables adjusted for market differences.
For quoted commodities, file the pricing communication before each shipment starts.
For intragroup services, keep evidence of the benefit received (deliverables, time records, cost allocation keys).
Check revenue against the 2,300 and 20,000 UIT thresholds each year and file the Local, Master and Country by Country Reports on SUNAT's schedule.
Consider a unilateral or bilateral advance pricing agreement for large recurring flows.

Common traps

Transactions with unrelated parties in low or no tax jurisdictions are also subject to the rules.
A missing or late commodity pricing communication moves the quotation date to the end of shipment or unloading, which may be costlier.
Management fees without a passed benefit test are not deductible, regardless of the price.
Discounted cash flow cannot support a share valuation when the stake sold is under 5 percent or the issuer's revenue is 1,700 UIT or less.

Sources

Related: Peru country profile · live dashboard · central bank and release calendar · our posts on X · where Argentina is involved, see The Argentine Thread guide

← IGV in Peru: the 18 percent value added tax, the 2026 to 2029 shift to the municipal tax, input credit, foreign services, exports and refundsInterest deduction limits in Peru: the 30 percent of EBITDA cap, its exemptions, carryforward and related party interest →

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