Amendments to the income tax law (DL 1662 and 1663) published on September 24, 2024, introduce the following changes to the transfer pricing regime effective January 1, 2025:
- “Rollback” of bilateral advance pricing agreements (APAs), allowing the terms agreed upon in a bilateral APA to be applied to periods prior to the conclusion date of the agreement
- New valuation methods for valuing shares and other assets:
- Discounted cash flows (DCF) (cannot be used to value shares representing small percentage of company (i.e., less than 5%) or in a company with revenues less than 1,700 UIT)
- Multiples
- Equity participation value
- Appraisal
- Multiperiod excess earnings method (MEEM) (for valuing assets other than shares)
Read a September 2024 report prepared by the KPMG member firm in Peru