Peru Transfer Pricing Documentation Requirements
Peru administers its documentation regime through informative returns geared to tax units. A Local File informative return applies above a revenue and transaction threshold, with the depth of the appendices scaling with the size of the dealings, and a Master File informative return applies to larger taxpayers.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
Master File Informative return
Required | Individual revenue > 20,000 tax units and related-party / tax-haven transactions > 400 tax units | October tax-period schedule of the following year | Submission deadline The documentation must be filed with the tax authority by the date shown. | ES | Yes (around USD 32,000 for failure) |
Local File Informative return (Annexes I–III)
Required | Revenue > 2,300 tax units and related-party transactions > 400 tax units (tiered appendices) | June tax-period schedule of the following year | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 7 days. | ES | Yes (around USD 32,000 for failure to keep the information) |
CbC report Required | Group revenue ≥ PEN 2,700m | 12 months after fiscal year-end | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
Calculate your exact Peru deadline
Enter your entity’s fiscal year-end to return your exact Peru preparation or filing date. Available without registration.
Scope of the documentation obligation
The Local File informative return is required where a taxpayer’s annual revenue exceeds 2,300 tax units and its transactions with related parties exceed 400 tax units. The return is structured in appendices that scale with the size of the dealings, so that the first appendix is triggered at a lower transaction level and the fuller appendices at a higher one. The Master File informative return applies at a higher level, where individual revenue exceeds 20,000 tax units and intercompany and tax-haven transactions exceed 400 tax units. Documentation is produced within seven days of a request.
Distinctive features of the Peruvian regime
The defining feature of the Peruvian regime is the tiered Local File informative return, in which the depth of disclosure rises in steps with the value of the related-party transactions rather than applying a single fixed standard. The filing calendar is geared to the monthly tax schedule: the Local File return follows the schedule for taxes due in the period covering May of the following year, while the Master File and Country-by-Country returns follow the schedule for the period covering September. The penalty for failing to keep the Local File information is around USD 32,000, and there is no safe harbour. Segmented financial statements must be prepared where applicable.
Benchmarking and comparables
Local, regional, and global comparable operations are all accepted by law. A 2021 ruling clarified that financial information from two or more years before or after the year under analysis may be used to assess comparability, but the regulations do not contemplate multiple years for determining the interquartile range itself. As a matter of good practice, the financials of comparables are updated for searches conducted a year earlier, with a full fresh search for those conducted two or more years previously. The limitation period for income tax assessments is four years after 1 January of the year following the year the return is due, extended to six years where returns were never filed.
Frequently asked questions
How does the Peruvian Local File informative return scale?
It is tiered. The first appendix is triggered at a lower transaction level and the fuller appendices at a higher one, so the depth of disclosure rises with the value of the related-party transactions.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.