ZR
TRANSFER PRICING
Diagnostic Consulting and Intra-Group Services and Transfer Pricing
We analyze in detail your intercompany share services transactions, loans with shareholders, intangible contracts (brands, etc.) with partners and between related companies within and outside the country, from a tax perspective.
This service involves preparing a Technical Transfer Pricing Study (ETPT) according to the specific needs of your company.
We support you in the review and/or determination of your agreed economic and tax values, whether or not you have Technical Transfer Pricing Studies (ETPT) from previous years; this diagnosis could also be omitted and the advice prepared based on the parameters that your company and staff explain to us and that have been identified by you.
The ETPT will contain an analysis of the commercial operations or transactions carried out by your company with national related companies and shareholders and/or companies from, to or through low or zero tax countries; in order to establish the valuation method for each type of transaction and to be able to determine its market value.
Since current legislation and treaties signed by Peru are always part of our analysis premises, as well as the possible incorporation into the OECD, we always use the “BEPS perspective” in our consultancy, as well as the approach to tax reforms and/or potential new criteria that SUNAT itself could adopt.
Our service ends with the delivery of a report containing the ETPT with the market value