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Peru's Income Tax Law has been amended in order make a number of key changes to current transfer pricing rules, including:

  • Expanded scope of application of the transfer pricing method for the assessment of commodity transactions, transactions carried out through international intermediaries or through tax haven countries and territories, to all imports and exports of products with market quotation
  • Implementation of the three-tiered reporting method (Local file, Master file and Country-by-Country Report) in line with OECD standards
  • Possibility to apply transfer pricing methods other than those stated in Peruvian transfer pricing legislation
  • Inclusion of the benefit test for the deduction of costs and expenses related to the payment of services received
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