What is Transfer Pricing? A Guide for Companies

July 11, 2024

Introduction

Transfer Pricing is a crucial concept in tax compliance and international taxation. Understanding them and their operating procedures is critical for any business operating with related entities. In this article, we will address in detail Transfer Pricing, its importance, and its regulations.   

Definition of Transfer Pricing

Transfer Pricing refers to the values assigned to commercial and financial transactions among related companies. These transactions may include the sale of goods, provision of services, use of intangibles, and financing, among others.   

Transfer PricingImportance

  • Tax Transparency: Transfer Pricing ensures that related company transactions are at market values, avoiding mispricing to reduce the tax burden.   
  • Prevention of Tax Base Erosion: It prevents the transfer of profits to jurisdictions with lower tax rates, ensuring a fair distribution of tax revenues among countries.   
  • Regulatory Compliance: Tax authorities worldwide, including those in Peru, require companies to comply with Transfer Pricing regulations to avoid tax adjustments and penalties.  

International and Local Transfer Pricing Regulations

Transfer Pricing regulations are aligned with the Organization for Economic Cooperation and Development (OECD) Guidelines and vary by jurisdiction. In Peru, the SUNAT (Superintendencia Nacional de Aduanas y de Administración Tributaria – National Superintendency of Tax Administration) establishes the specific obligations companies must comply with regarding Transfer Pricing documentation and reporting.  

Documentation and Compliance

In order to comply with Transfer Pricing regulations, companies must prepare and maintain adequate documentation to support the Transfer Pricing policies used. They include:   

  • Local Report: Transaction details and comparability analysis.   
  • Master File: Global information on the multinational group.   
  • Country-by-Country Report: Tax and economic data itemized by country.   

Conclusions and Recommendations

Understanding Transfer Pricing and its importance is essential for any company operating internationally. Complying with regulations is not only a legal obligation but also protects companies from tax risks and penalties. At TPC Group, we offer specialized advice to assist you in effectively understanding and complying with Transfer Pricing regulations.   

Call to Action

For further questions regarding Transfer Pricing, please contact us at TPC Group for customized consulting and to ensure compliance with your tax obligations.   

Source: SUNAT (National Superintendence of Tax Administration), OECD (Organization for Economic Cooperation and Development).