Sign up for tax alert emails    GTNU homepage    Tax newsroom    Email document    Print document    Download document

October 2, 2020
2020-6275

Peru’s Tax Authority postpones filing of CbC report for 2019 tax year

On 28 September 2020, the Peruvian Tax Authority published Ruling No. 000155–2020, which indefinitely postpones the filing of the Country-by-Country (CbC) reports for the 2019 tax year, for Peruvian taxpayers that are members of a multinational enterprise (MNE) group whose ultimate parent entity (UPE) is a nonresident related party. Specifically, the due date is postponed for taxpayers that meet any of the following conditions:

  • Taxpayers whose nonresident parent entity is not required to file the CbC report in their jurisdiction of residence
  • Taxpayers resident in Peru that had to submit the CbC report because the jurisdiction of the parent’s residence has an international treaty or Andean Community decision (i.e., a decision from the free trade area comprising Bolivia, Colombia, Ecuador and Peru) in effect with Peru that authorizes the exchange of tax information, but does not have a qualifying competent authority agreement in effect with Peru for the exchange of the CbC report
  • Taxpayers with a UPE resident in a jurisdiction (i) with an international treaty or Andean Community decision (ii) with an agreement in effect between competent authorities and (iii) in which systematic failure of the tax information exchange has been communicated by Peruvian tax authorities to the taxpayer resident in Peru

The deadline for submitting the 2019 CbC reports is now aligned to the 2017 and 2018 postponements. For the three tax years of 2017, 2018 and 2019, the due date will be the last business day of the month following the month in which the Peruvian tax authority publishes on its website that Peru has met the standard of confidentiality and security for information, as required by the Organisation for Economic Co-operation and Development.

Unlike tax years 2018 and 2019, the postponement for tax year 2017 applied only to taxpayers resident in Peru that had to submit the CbC reports because the jurisdiction of the UPE’s residence has an international treaty or Andean Community decision in effect with Peru that authorizes the exchange of tax information, but does not have a qualifying competent authority agreement in effect with Peru for the exchange of the CbC report.

_____________________________________________________________________________________________________________

For additional information with respect to this Alert, please contact the following:

Ernst & Young Asesores S.C.R.L, Lima
Ernst & Young LLP (United States), Latin American Business Center, New York
Ernst & Young Abogados, Latin America Business Center, Madrid
Ernst & Young LLP (United Kingdom), Latin American Business Center, London
Ernst & Young Tax Co., Latin American Business Center, Tokyo

ATTACHMENT

 

 
 

The information contained herein is general in nature and is not intended, and should not be construed, as legal, accounting or tax advice or opinion provided by Ernst & Young LLP to the reader. The reader also is cautioned that this material may not be applicable to, or suitable for, the reader's specific circumstances or needs, and may require consideration of non-tax and other tax factors if any action is to be contemplated. The reader should contact his or her Ernst & Young LLP or other tax professional prior to taking any action based upon this information. Ernst & Young LLP assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect the information contained herein.

 

Copyright © 2024, Ernst & Young LLP.

 

All rights reserved. No part of this document may be reproduced, retransmitted or otherwise redistributed in any form or by any means, electronic or mechanical, including by photocopying, facsimile transmission, recording, rekeying, or using any information storage and retrieval system, without written permission from Ernst & Young LLP.

 

Any U.S. tax advice contained herein was not intended or written to be used, and cannot be used, by the recipient for the purpose of avoiding penalties that may be imposed under the Internal Revenue Code or applicable state or local tax law provisions.

 

"EY" refers to the global organisation, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients.

 

Privacy  |  Cookies  |  BCR  |  Legal  |  Global Code of Conduct Opt out of all email from EY Global Limited.

 


Cookie Settings

This site uses cookies to provide you with a personalized browsing experience and allows us to understand more about you. More information on the cookies we use can be found here. By clicking 'Yes, I accept' you agree and consent to our use of cookies. More information on what these cookies are and how we use them, including how you can manage them, is outlined in our Privacy Notice. Please note that your decision to decline the use of cookies is limited to this site only, and not in relation to other EY sites or ey.com. Please refer to the privacy notice/policy on these sites for more information.


Yes, I accept         Find out more