Peruvian tax questions look different from headquarters. We help foreign groups understand withholding on payments abroad, treaty relief, transfer pricing and IGV before a contract is signed or an invoice is paid.
A short overview for planning conversations with headquarters. The treatment of any specific transaction depends on its facts and documentation.
| Tax | General rule | Why it matters to a foreign group |
|---|---|---|
| Corporate income tax | 29.5% of net taxable income, with monthly prepayments | Drives the effective tax rate of the subsidiary and which intercompany costs are deductible |
| Dividends | 5% withholding on dividends paid to non-domiciled shareholders | The main cost of repatriating profits from a subsidiary |
| Payments for services abroad | Generally subject to withholding, commonly 30%; technical assistance can be 15% when requirements are met | Management fees, royalties and services from the parent are taxed in Peru before they leave |
| IGV (VAT) | 18% | Also applies to services from non-domiciled suppliers used in Peru |
| Transfer pricing | Arm's-length standard for related-party transactions; documentation above certain thresholds | Intercompany prices and charges must be supportable |
Most of the questions we receive from foreign groups relate to money moving between Peru and the rest of the group.
Management fees, royalties, technical assistance, cost recharges and services: the withholding, the IGV and whether the cost is deductible in Peru.
Whether a treaty may reduce withholding, which residence certificate is needed and how to keep the file ready for SUNAT.
Arm's-length support for intercompany prices, the benefit test for intragroup services and the documentation that may be required.
Loans from the parent or group treasury: withholding on interest, interest deductibility and how the loan is documented.
Dividends, capital reductions and other ways to return cash to the group, and their tax effects in Peru.
IGV on local sales, on services from abroad and on imports, and how to protect the input VAT credit.
Group tax departments need conclusions they can file and defend. We set out the facts we relied on, the rule applied, the risks we see and the actions required in Peru, in English.
We do not start from a generic tax-saving promise. We look at the actual contracts, invoices and flows.
Contracts, invoices, group structure and the decision to be made, including the countries involved.
Peruvian rules, applicable treaty and documentation gaps, with material uncertainties identified.
Practical alternatives, their risks and the actions needed in Peru.
Coordination with accounting so withholding, IGV and entries reflect the conclusion.
Specific questions are quoted per matter. Groups with recurring cross-border activity often prefer a monthly scope that combines compliance and advisory; see our reference fee ranges. Monthly filings belong to accounting outsourcing; restructurings and distributions are covered under tax planning.
Quoted separately: transfer pricing studies, formal tax opinions for third parties and SUNAT audit defense.
The tax profile of a Peruvian entity is largely defined when it is created: vehicle, shareholders and how it will be funded. We review those points as part of the incorporation project.
Company incorporation for foreign investors →It depends on what is being paid. Services provided by a non-domiciled entity are generally subject to income-tax withholding, commonly at 30%, and technical assistance can be taxed at 15% when the requirements are met. Dividends to non-domiciled shareholders carry a 5% withholding. We review the contract and invoice before the first payment.
It may. Peru has double tax treaties with the Andean Community countries (Bolivia, Colombia and Ecuador, through Decision 578), Brazil, Canada, Chile, Japan, Mexico, Portugal, South Korea and Switzerland. Treaty benefits require a tax residence certificate from the foreign recipient, so it should be obtained before the payment is made.
Yes. Transactions between the Peruvian entity and related parties abroad must follow arm's-length pricing, and above certain thresholds they require documentation such as a local file or master file. The services must also be real and supported by evidence of the benefit received.
Services provided by a non-domiciled supplier and used in Peru are generally subject to IGV (18%) under the use-of-services rules. The Peruvian company pays it and can normally use it as input VAT credit, provided the formal requirements are met.
No. Monthly filings are part of our accounting outsourcing service. Tax advisory covers specific questions and transactions, quoted per matter or as a retainer.
Send us the contract or a short description of the flow, the countries involved and the expected date. We will define the scope of review.