The National Superintendency of Customs and Tax Administration (SUNAT) has granted an exceptional extension of the deadline for filing the Local File Informative Affidavit for the 2025 tax year, a measure of particular importance for taxpayers subject to the Transfer Pricing regime in Peru.
This provision was established by Superintendency Resolution No. 113-2026/SUNAT, published in the Official Gazette *El Peruano*, and addresses the need to adapt Virtual Form No. 3560 to recent regulatory changes introduced in Transfer Pricing legislation.
New Deadline for Filing the Local File
According to the resolution issued by SUNAT, the filing of the Informative Affidavit—Local File for the 2025 fiscal year must be completed by the due dates set for tax obligations for the October 2026 period.
This exceptional extension is due to the fact that the Tax Administration is implementing adjustments to Virtual Form No. 3560 in order to incorporate the recently approved regulatory changes and ensure the proper collection of the required information.
Relation to Transfer Pricing Amendments
The extension of the deadline is related to the amendments incorporated into paragraph 7 of subsection (e) of Article 32-A of the Income Tax Law, which pertain to the valuation methods applicable to transactions between related parties.
As a result of these changes, SUNAT needs to adapt its IT tools to enable the accurate reporting of information and facilitate the assessment of transactions subject to the arm’s-length principle.
Who Is Required to File the Local File?
The Local File is one of the main formal obligations under the Transfer Pricing regime and is intended to provide the Tax Administration with detailed information on transactions conducted with related parties or with entities resident in low- or no-tax jurisdictions.
The obligation to file this informative report falls on taxpayers who meet the criteria established by current regulations, taking into account both income levels and the conduct of transactions falling within the scope of the Transfer Pricing rules.
Therefore, it is advisable for taxpayers to assess their intercompany transactions in a timely manner and verify compliance with the requirements established by SUNAT to determine whether they are required to file the Local File.
Implications for Taxpayers
While the extension provides some relief in terms of formal compliance, it does not alter the substantive obligations arising from the Transfer Pricing regime. Consequently, taxpayers should take advantage of this additional time to review the consistency of their economic analyses, validate the supporting documentation for their related-party transactions, and ensure that the reported information is in line with current regulations.
Likewise, companies that are part of multinational groups must verify the consistency between their local documentation and the information contained in other Transfer Pricing reports, thereby strengthening their position in the event of future tax audits.
SUNAT’s decision to extend the filing deadline for the 2025 Local File stems from the need to adapt Virtual Form No. 3560 to recent regulatory changes regarding Transfer Pricing. This measure provides taxpayers with additional time to prepare and validate the required information, without altering the substantive obligations set forth in Peruvian law.
At TPC Group, we advise companies across various sectors on compliance with their Transfer Pricing obligations, providing specialized solutions in documentation, tax planning, and defense during audits. Our multidisciplinary team has extensive experience in Latin America and stays abreast of regulatory developments to help organizations efficiently manage their tax risks.
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