On 14 May 2026, Peru’s National Superintendency of Customs and Tax Administration updated its guidance on mutual agreement procedures (MAPs) in both English and Spanish. The guidance explains the legal framework, eligible disputes, and available resolution methods, including unilateral, bilateral, and multilateral procedures. It also confirms a general three-year deadline to request a MAP and outlines possible reductions in penalties and interest rates. The update further addresses advance pricing agreements within the MAP framework.
To access the Guidance in English, click here.
To access the Guidance in Spanish, click here.
On September 24,2024, the Peruvian Official Gazette published Legislative Decree No. 1663, which updates the income tax law regarding transfer pricing valuation methods. This decree allows for alternative valuation methods when standard approaches are not suitable due to the nature of the transaction or the lack of reliable independent transactions.
For instance, it introduces the discounted cash flow method, multiples method, equity value method, and appraisals for determining market value of unlisted shares. Additionally, it permits the multi-period excess earnings method (MPEEM) for certain transactions. Important to note, the discounted cash flow method can’t be used if the transferor owns less than 5% of the shares or if the issuing company’s net income was less than 1,700 tax units last year.
The decree will take effect on January 1, 2025.
To learn more about the Decree, click here.