PERU MASTER REPORT: WHAT WE SHOULD KNOW

Which taxpayers are required to submit the 2018 Master Report?

• The members of a group,
• That register income greater than S / 83’000,000, and
• That record transactions in the scope of transfer prices equal to or greater than S / 1,660,000

*All 3 conditions must be met during the same fiscal year.

What transactions are included in the scope of transfer pricing?

• Those made with related / related parties.
• Those made with related / related parties.
• Those carried out with subjects whose income, income or profits from said transactions are subject to a preferential tax regime.

What countries or territories are considered “tax havens”?

• In total there are 44 and includes Panama, Hong Kong, Cayman Islands, Bahamas, Virgin Islands, Andorra, Saint Vincent and the Grenadines, Saint Lucia, among others.
• Luxembourg, the Netherlands, Taiwan and China are not included.

What is a group?

• Group of people, companies or entities linked by ownership or control relationships and is obliged to formulate consolidated financial statements or who would be obliged to do so if the shares, participations or other documents representative of the patrimony were negotiated in centralized trading mechanisms (eg: Stock Exchange of Securities).

Who are members of a group?

• People, companies or entities included in the consolidated financial statements of a group.
• Persons, companies or entities excluded in the consolidated financial statements of a group only for reasons of size or relevance.
• The permanent establishments.

Who is the parent of a group?

• The member of a group who has direct or indirect control over the other members of said group.
• It formulates consolidated financial statements or it would be obligated if the shares, participations or other representative documents of the patrimony were negotiated in centralized negotiation mechanisms.
• There must not be another member of the group that exercises similar control over that group.

(*) All 3 conditions must be met during the same fiscal year.
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