• Transfer Pricing

Transfer Pricing

Transfer Pricing Documentation

Companies performing transactions with related parties or entities domiciled in tax havens must be able to provide SUNAT with Transfer Pricing documentation, which must prove and support the that the transactions involved have been conducted under the arm’s length principle. BDO Peru has global Transfer Pricing expertise, which will allow you to organize the documentation that meets local requirements.

Our services include:

  • Prepare Technical Transfer Pricing Studies
  • Provide assistance in the preparation of the Annual Informative Declaration of Transfer Prices
  • Gather the documentation and information referred to in Article 116 of the Regulations of the Income Tax Law.

Resolution of Controversies

Tax authorities often question the prices agreed on transactions conducted between related parties. Our Transfer Pricing professionals can assist your company in handling any dispute related to this matter. In the case of an audit or tax investigation, we can help you develop a defense strategy based on both local regulations and international jurisprudence. Our experienced team will assist you when facing potential Transfer Pricing adjustments, or to negotiate APAs. Additionally, we can assist you in lawsuits relating to this matter.

Our services include:

  • Assist the company in tax audits or tax lawsuits relating to compliance with Transfer Pricing regulations.
  • Provide assistance in negotiating, executing and implementing Advance Pricing Agreements (APAs).


Transfer Pricing documentation must contain the necessary economic and legal support to demonstrate that the price agreed for transactions with related parties or entities residing in tax havens are set at market value. BDO Peru can assist you in setting the prices or margins of the transactions under analysis.

Our services include:

  • Prepare special reports of market value ranges
  • Prepare prospective and cost-benefit analyses of corporate policies, for tax and/or business purposes
  • Provide the economic basis to develop policies and new business models, or to support those currently being applied, as well as the corporate or internal decisions behind them.

Efficient Management of Tax Value Chain

Companies often seek to change their business models to add value to their clients and shareholders. Whether you need to enter new markets, establish a central supply channel, transfer production processes to countries with lower costs, relocate central management or integrate acquisitions, BDO Peru can help you manage the risks related to Transfer Pricing, and the tax position of the economic group in a sustainable manner.

Our services include:

  • Offer tax value chain and transfer pricing planning services
  • Perform analyses of potential expenses of ceasing operations, the risks related to the incorporation of permanent establishments, and the preservation of tax benefits as a result of the movement of functions, assets and risks.