Next Master File Due Date in Peru
The Transfer Pricing affidavits were modified as of the fiscal year 2016, giving rise to three levels of affidavit in this matter: Local Report, Master File, and Country by Country Report.
Being two of these latter required as of fiscal year 2017.
Master File Requirement in Peru
According to Legislative Decree No. 1312 and Superintendence Resolution No. 163-2018/SUNAT (Superintendencia Nacional de Aduanas y de Administración Tributaria or National Superintendence of Customs and Tax Administration), the member taxpayers of an economic group must file the Informative Affidavit of Master Report if they meet the following conditions:
- The accrued income for the taxable year must have exceeded 20,000 UIT (Unidades Impositivas Tributarias or Tax Units) as S/. 86,000,000 for the year 2020.
- Performing transactions within the application scope of the Transfer Pricing rules for an amount equal to or greater than 400 UIT (S/. 1,720,000 for fiscal year 2020).
It should be noted that the regulation states that a “group” is defined as a group of related persons, companies or entities, under the provisions of paragraph 1 of subsection a) of Article 116 of the regulation”.
Master File Content
Under the provisions of Annex I of Superintendency Resolution No. 163-2018/SUNAT, the Master Report must contain information on the organizational structure of the group, the description of the business or businesses of the group members, the economic group policies regarding intangibles, financing of the group, as well as the financial and tax position of its members.
Master File Due Date Schedule
The Informative Affidavit Master File must be filed according to the due dates schedule approved for the affidavit and payment of monthly liquidation taxes corresponding to the September tax period of the taxable year following the one to which the affidavit corresponds.
If the fiscal year 2020, the affidavit Master Report would expire in October 2021, depending on the dates the last digit of the taxpayer’s TIN (Tax Identification Number), according to SUNAT’s Superintendence Resolution.