What is Transfer Pricing? A Guide for Companies

July 11, 2024


Transfer Pricing is a crucial concept in the field of tax compliance and international taxation. Understanding what they are and how they work is critical for any business that transacts with related entities. In this article, we will explore in detail what transfer pricing is, its importance and the regulations that govern it.  

Definition of Transfer Pricing  

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

Importance of Transfer Pricing  

  • Fiscal Transparency: Transfer Pricing ensures that transactions between related companies are carried out at market values, avoiding price manipulation to reduce the tax burden.  
  • Prevention of Tax Base Erosion: Helps prevent the transfer of profits to jurisdictions with lower tax rates, ensuring a fair distribution of tax revenues between countries.  
  • Regulatory Compliance: Tax authorities around the world, 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 Co-operation and Development (OECD) guidelines and vary by jurisdiction. In Peru, the National Superintendency of Tax Administration (SUNAT) establishes the specific obligations that companies must comply with in relation to transfer pricing documentation and reporting.  

Documentation and Compliance  

To comply with transfer pricing regulations, companies must prepare and maintain adequate documentation to support the transfer pricing policies used. This includes:  

  • Local Reporting: Transaction detail and comparability analysis.  
  • Master Report: Global information on the multinational group.  
  • Country-by-Country Report: Tax and economic data broken down 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 help you understand and comply with transfer pricing regulations in an effective manner.  

Call to Action  

Do you have questions about transfer pricing? Contact us at TPC Group to get personalized consulting and ensure compliance with your tax obligations.  


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