Transfer Pricing

The companies that conduct operations with related companies or those residing in tax heavens should be able to provide SUNAT with Transfer Price-related documentation, which should prove and support the nature of full competition of transactions.

At present, BEPS introduced significant changes in international taxation regulations. In view of these needs, our highly qualified multi-disciplinary team with experience at international level, is willing to accompany you in different stages of compliance with formal Transfer Price obligations, both at domestic and international level.

We provide the following services:

  • Preparation and submission of transfer price sworn statements:
    • local report: Virtual Form 3560
    • master report: Virtual Form 3561
    • country by country report: IR AEOI System
  • Prevention of possible disputes for inter-related operations (APAs)
  • Assistance in tax inspections
  • Preparation of a tax model for exploitation of a multinational company and its global tax objectives.
  • Benchmarking and comparability analysis
  • Conduction of a prospective and cost-benefit analysis of corporate policies, for tax and/or business purposes
  • Provision of economic support for the development of policies and new business models, or support to those which are being applied and corporate or internal decisions behind them
  • Advice on operations of mergers, acquisitions, absorptions, reorganizations and similar ones