Peru Tax Agency Issues Updated Guidance on Mutual Agreement Procedure in English, Spanish

The Peruvian National Superintendency of Customs and Tax Administration May 14 issued updated guidance, in English and Spanish, on the mutual agreement procedure (MAP). Topics covered include: 1) the legal framework of the MAP, including under nine DTAs signed by Peru and the Pacific Alliance Framework Agreement and protocol; 2) the Tax Agency as the Peruvian competent authority for the MAP; 3) types of matters eligible for the MAP, including residence conflicts, income tax withholding issues, permanent establishment (PE) determinations, and transfer pricing adjustments; 4) MAP modalities, including unilateral resolution by the Tax Agency, and bilateral or multilateral resolution involving ...