Data points
- Accrued income that triggers the local file, about PEN 12,305,000 at the 2025 unit[2]
- 2,300 UIT
- Group income that triggers the master file, alongside 400 UIT of transactions[3]
- 20,000 UIT
- Consolidated group revenue that triggers the country by country report[4]
- PEN 2.7bn
- Of net income, for a late, missing or incomplete informative return[7]
- 0.6%
- Cap on the documentation penalty, 25 tax units at the 2025 value[7]
- PEN 133,750
- One off filing window for the 2025 local file, 16 to 24 November by RUC digit[6]
- Nov 2026
- The 2025 tax unit every threshold is converted from[1]
- PEN 5,350
Peru does not keep transfer pricing documentation on file for production on request. It files it, as three sworn informative returns, in Spanish, on the tax authority's monthly schedule.
The four facts to know:
- The local file is required once accrued income passes 2,300 UIT, about PEN 12,305,000 at the 2025 tax unit of PEN 5,350.
- The master file is required when group income passes 20,000 UIT and your own in-scope transactions reach 400 UIT or more. Both conditions, not either one.
- The country by country report is required at PEN 2,700,000,000 of prior year consolidated group revenue.
- A late, missing or incomplete return costs 0.6% of net income.
Which transfer pricing returns does Peru require?
Three, and all three are filed. The Reporte Local is the local file, the Reporte Maestro is the master file, and the Reporte País por País is the country by country report. They go to SUNAT, the Superintendencia Nacional de Aduanas y de Administración Tributaria, on its monthly obligation calendar. This is the structural fact that separates Peru from countries where the master file and local file are only prepared and produced when an auditor asks.
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| OECD document | Peru return | Form | Source |
|---|---|---|---|
| Local file | Reporte Local | Form Virtual 3560 | SUNAT, Peru |
| Master file | Reporte Maestro | Form Virtual 3561 | SUNAT, Peru |
| Country by country report | Reporte País por País | Not confirmed on the authority's own page | SUNAT, Peru |
Every threshold below is expressed in UIT, the Unidad Impositiva Tributaria, a tax unit reset by decree each year. The 2025 unit was PEN 5,350, as recorded in the OECD transfer pricing country profile for Peru[1] updated in October 2025. Soles figures on this page use that value and say so.
Who has to file transfer pricing returns in Peru?
Any entity domiciled in Peru whose related party or tax haven transactions pass the thresholds. The duty sits with the Peruvian entity, not with the foreign parent, although the parent's group figures are what decide the master file and country by country tests. Income and transaction volume trigger it, both measured in tax units.
Two parties are related where one owns more than 30% of the other's capital, directly or indirectly, or where the same people hold more than 30% of two or more entities. Shared directors or executives with decision making power count, so does dominant influence. There is also a trade dependency test: 80% or more of one party's sales going to a counterparty that supplies at least 30% of its purchases makes them related with no ownership at all.
What are Peru's transfer pricing thresholds for 2026?
Four tests, keyed to the tax unit, so the soles figures move every year. The local file has an income trigger and then two content tiers set by transaction size. The master file needs both of its conditions met. The country by country threshold is the one that is fixed in soles rather than in tax units. SUNAT publishes the local file rules[2] and the two annex tiers.
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| Obligation | Threshold in tax units | Approximate soles at the 2025 unit of PEN 5,350 | Source |
|---|---|---|---|
| Local file income trigger | Accrued income above 2,300 UIT | PEN 12,305,000 | SUNAT, Peru |
| Local file, Annex I only | Transactions of 100 UIT to under 400 UIT | PEN 535,000 to under PEN 2,140,000 | SUNAT, Peru |
| Local file, Annexes II to IV | Transactions of 400 UIT or more | PEN 2,140,000 or more | SUNAT, Peru |
| Master file | Group income above 20,000 UIT and transactions of 400 UIT or more | PEN 107,000,000 and PEN 2,140,000 | SUNAT, Peru |
| Country by country report | Prior year consolidated group revenue of PEN 2,700,000,000 or more | Fixed in soles, so it does not move with the unit | SUNAT, Peru |
| 2026 tax unit value | Set by decree each year | Not confirmed. The 2025 unit was PEN 5,350 | OECD |
The master file test is joint. A group over 20,000 UIT of income whose Peruvian entity transacts below 400 UIT does not file one, and SUNAT sets out both conditions[3] on its master file page.
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Does Peru require a country-by-country report?
Yes, from PEN 2,700,000,000 of prior year consolidated group revenue. SUNAT publishes the threshold and the notification rule[4]. The return goes in on the September period schedule of the following year.
The notification is where foreign parented groups get caught. A designated filer has to notify the authority by the last business day of the month before the filing deadline. Where no filer is designated, every group member domiciled in Peru is responsible for the return, so one missed designation turns a single group obligation into exposure for each local entity.
When are Peru's transfer pricing returns due?
On the monthly obligation calendar, keyed to the last digit of the taxpayer's RUC, the Peruvian tax identification number. There is no single date that covers every filer. The exact day moves by RUC digit within the scheduled period, and the resolution behind the master file and the country by country return[5] ties both of them to the September period.
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| Return | 2026 deadline | Source |
|---|---|---|
| Local file, Form Virtual 3560 | May period schedule of the following year, by RUC digit | SUNAT, Peru |
| Local file for 2025 only | Moved to the October 2026 period, filed 16 to 24 November 2026 by last RUC digit | SUNAT, Peru |
| Master file, Form Virtual 3561 | September period schedule of the following year | SUNAT, Peru |
| Country by country report | September period schedule of the following year | SUNAT, Peru |
| Country by country designated filer notice | Last business day of the month before that deadline | SUNAT, Peru |
The 2025 local file moved once, and only once. SUNAT pushed it from the May 2026 period to the October 2026 period[6] because a legislative change to the rules on other methods meant Form Virtual 3560 had to be rebuilt first. Treat the May period as the normal date and November 2026 as the one off.
What language and currency must the returns use?
Spanish, for every informative return and every piece of supporting information. Amounts are keyed to the tax unit and to the Peruvian sol. Group level figures in the master file and the country by country report that start life in another currency are presented in soles on the Peruvian return.
What are the penalties for getting Peru transfer pricing wrong?
A late, missing or incomplete informative return costs 0.6% of net income. A separate failure to produce the supporting documentation when asked carries the same 0.6% rate, with a floor and a cap denominated in tax units. SUNAT publishes the infraction and penalty schedule[7] that sets both.
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| Infraction | Penalty | Source |
|---|---|---|
| Informative return late, missing, incomplete or not conforming | 0.6% of net income | SUNAT, Peru |
| Filing outside the prescribed form or conditions | 30% of one tax unit, PEN 1,605 at the 2025 unit | SUNAT, Peru |
| Failure to produce the supporting documentation on request | 0.6% of net income, floor 10% of one tax unit (PEN 535), cap 25 tax units (PEN 133,750) | SUNAT, Peru |
What is a foreign parent exposed to?
The Peruvian entity carries the filing duty and the penalty, but the parent carries the data that decides two of the three returns. Consolidated revenue, the group structure and the country by country dataset all come from the parent, and the Peruvian entity cannot file without them.
The notification is the practical trap. With no designated filer, every Peru domiciled member of the group is on the hook for both the notice and the return. A group that assumed its parent jurisdiction would exchange the report automatically can find each Peruvian entity separately liable.
How does Peru differ from the OECD transfer pricing baseline?
Peru follows the OECD Transfer Pricing Guidelines largely, as a source of interpretation where they do not contradict Peruvian law. Peru is not an OECD member. It is an accession candidate and an Inclusive Framework member, and that membership is how the three tier documentation standard entered Peruvian law as filed returns rather than kept records.
The differences are concrete. The related party ownership test is 30%, not the 25% or 50% used elsewhere. Local comparables are preferred over regional sets. The markup on low value-adding services is capped at 5% of the provider's costs. Unilateral advance pricing agreements are available with the tax authority, while the rules for bilateral and multilateral agreements were still pending as of October 2025, so those are not something you can apply for yet.
How we help with Peru transfer pricing
Peru's three returns land on three different schedules, each keyed to a RUC digit, and the thresholds move every time the tax unit resets. We work out which of the three your entity owes, build the local comparables Peru prefers, prepare the local file and master file content, and file on the right period. See how our transfer pricing software works.
Book a demo to get your Peru filing obligations checked against the current tax unit before the next deadline.
Official sources
7 sources
- 1.OECD. Transfer pricing country profile: Peru (updated October 2025)
- 2.SUNAT, Peru. Sworn informative return: Reporte Local (local file) guidance
- 3.SUNAT, Peru. Sworn informative return: Reporte Maestro (master file) guidance
- 4.SUNAT, Peru. Sworn informative return: Reporte País por País (country by country report) guidance
- 5.SUNAT, Peru. Superintendency Resolution 163-2018: master file and country by country returns
- 6.SUNAT, Peru. Superintendency Resolution 000113-2026: local file deadline for the 2025 fiscal year
- 7.SUNAT, Peru. Tax Code, Table I: infraction and penalty schedule
Article by
Sam Suechting
Head of Product, Commenda
Sam is a seasoned expert in sales tax, leading Commenda's effort to build the worlds most comprehensive database of global tax rules and business regulations. At Silverhaze Partners, he worked in early-stage venture capital, where he saw firsthand how tax complexity and regulatory friction hold back startups from scaling internationally. That experience now powers his work at Commenda-bringing clarity, precision, and real-world insight to one of the most frustrating parts of doing business globally.
Disclaimer: Commenda and its affiliates do not provide tax, accounting, or legal advice. This material has been prepared for informational purposes only, and is not intended to provide or be relied on for tax, accounting, or legal advice. You should consult your own tax, accounting, and legal advisors before engaging in any related activities or transactions.
