Peru postpones some country-by-country report submissions

By Yasser Zola, Transfer Pricing Manager, BaseFirma Perú, Lima

On September 28, the Peruvian tax authority published Superintendency Resolution 000155-2020, postponing in certain cases the submission of the country-by-country reports on multinational group entities for fiscal year 2019.

The country-by-country reports postponed are those where the taxpayer has an ultimate parent entity that is is not required to submit the report in its country of residence; those involving countries where Peru has not established automatic exchange of information; or involving countries where there has been a systematic failure to exchange tax information.

The country-by-country reports have been postponed until the last business day of the month following the date that the Peruvian tax authority publishes on its website that it has approved the country’s confidentiality and security of information standards, as required by the OECD. 

Peru has signed and ratified the Multilateral Competent Authority Agreement on the Exchange of Country by Country Reports, but the agreement is not yet in force.  

This highly anticipated action taken by the Peruvian tax authority is the same as that of March 2019, when the country-by-country report submissions for FY 2018 and 2017 were also postponed.

The parent entity of the multinational group based in Peru or the taxpayer based in Peru that has been appointed by the group as the surrogate parent entity must still submit the country-by-country report from October 15—23, according to the last digit of their tax ID number, provided that the revenue accrued by the multinational group in the previous fiscal year is greater than or equal to PEN 2.7 billion (approximately USD 808 million).  

The Peruvian tax authority has an instruction site to help taxpayers comply with the formal obligation.

— Yasser Zola is Transfer Pricing Manager, BaseFirma Perú, Lima.