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Ramirez Enríquez y Asociados

Leading Authority & Transfer‑Pricing Advice In Peru

Ramírez Enríquez y Asociados is recognized in Peru for delivering integrated tax, audit, and transfer-pricing advisory services to domestic and multinational groups. The firm blends chartered accountancy strengths with specialized tax capability, establishing itself as the go-to adviser for transfer-pricing issues, compliance, and controversy matters. Ramírez Enríquez y Asociados is a member firm of an international accounting network, reinforcing its cross-border capacity to support complex intragroup arrangements and multinational documentation requirements. For clients seeking a transfer-pricing lawyer in Peru, the firm offers a robust, audit-driven approach that aligns accounting evidence with tax strategy.

Professional Background & Credentials

Ramírez Enríquez y Asociados is led by a senior team of Chartered Public Accountants and consultants, with a leadership group that combines deep training in accounting, audit, and tax. The firm’s public profile highlights Ana María Dávila as Socia Principal, alongside partners and managers who bring university qualifications, postgraduate training, and professional specialisations in audit and taxation. These credentials underpin Ramírez Enríquez y Asociados’ full‑service offering across audit, impuestos, outsourcing, and consulting.

In addition, the firm is a member of LEA Global, one of the world’s leading international associations of independent accounting, audit, tax, and advisory firms. This affiliation provides access to a global network of professionals and specialised knowledge across multiple jurisdictions, allowing us to deliver coordinated cross-border support, stay abreast of international regulatory developments, and obtain local expertise when addressing multinational operations.

Technical Expertise In Transfer‑Pricing

Ramírez Enríquez y Asociados advises on the full spectrum of transfer-pricing matters in Peru, from the preparation of the Local File (Reporte Local) and Estudio Técnico de Precios de Transferencia to transactional pricing and intercompany service policies. The firm’s tax practice routinely assists clients with EPT filings, documentation strategies, and benchmarking analyses necessary to demonstrate arm’s-length outcomes under Peruvian rules. These services are delivered by teams experienced in both accounting and tax methodology for comparability and cash-flow impacts.

What Distinguishes Ramírez Enríquez y Asociados & Transfer‑Pricing Capability

Ramírez Enríquez y Asociados offers a pragmatic blend of audit discipline and tax advisory focus, enabling the firm to craft defensible transfer-pricing positions supported by accounting evidence and commercial narratives. This multidisciplinary approach provides a critical advantage when SUNAT challenges intercompany pricing or the application of the “test de beneficio” for intragroup services. The firm emphasises documentation quality, appropriate selection of transfer-pricing methods, and proactive adjustments to avoid fiscal contingencies.

Notable Work, Publications & Thought Leadership

Ramírez Enríquez y Asociados maintains an active presence on tax and transfer-pricing developments, regularly publishing client alerts and analyses on rulings and administrative guidance. The firm has commented publicly on recent Tribunal Fiscal decisions and tax criteria affecting prorrata and deductible expenses, demonstrating hands-on engagement with the evolving Peruvian fiscal environment. Partners and managers participate in regional conferences and network events to broaden exposure to comparative transfer-pricing practices and case law.

Verified Engagements & Sector Experience

Ramírez Enríquez y Asociados maintains an established portfolio of audit and advisory engagements across private and public-interest entities, providing assurance and consultancy to organisations appearing in supervisory and sector reports.

The firm also has extensive experience advising clients across a wide range of industries, including commercial, services, manufacturing, banking and financial services, agriculture, and other key sectors of the Peruvian economy.

Context: Transfer‑Pricing Law & Compliance In Peru

Peru’s transfer-pricing regime is anchored in the Income Tax Law and SUNAT administrative rules, requiring informative annual declarations (Reporte Local) and, where applicable, a technical study supporting arm’s-length pricing. The rules recognise several OECD-aligned methods and impose specific requirements for intragroup services including the “test de beneficio” that conditions deductibility. Non-compliance or weak documentation can trigger significant assessments, penalties, and protracted administrative reviews.

Key Challenges & How REA Helps Clients

Peru-based businesses face recurring transfer-pricing challenges: identifying reliable comparables in thin markets, documenting complex supply-chain pricing, validating intragroup service value under the benefit-test, and responding to SUNAT audits or Tribunal Fiscal precedents. Ramírez Enríquez y Asociados addresses these risks by combining econometric benchmarking, transactional forensics, and narrative support that ties prices to business functions, assets, and risks. The firm also supports clients in tax audits, injunctions, and administrative appeals where technical documentation and accounting integrity are decisive.

Who Should Engage Ramírez Enríquez y Asociados

Ramírez Enríquez y Asociados is well-suited to Peruvian subsidiaries of multinational enterprises, export/import traders, family groups with cross-border arrangements, and local companies engaging with related-party services or financing. Businesses seeking a transfer-pricing lawyer in Peru will benefit from Ramírez Enríquez y Asociados’ audit-driven approach to documentation, its membership in an international professional network, and its practical experience with SUNAT and Tribunal Fiscal matters.

Final Note On Engaging A Transfer‑Pricing Lawyer In Peru

Effective transfer-pricing advice in Peru requires technical mastery of SUNAT rules, robust economic analysis, and disciplined documentation, plus dispute management skills for administrative reviews or litigation. Ramírez Enríquez y Asociados presents a multidisciplinary offering that aligns accounting rigour with tax strategy, helping clients reduce exposure, optimise documentation practices, and defend pricing positions with credible evidence. For Peruvian taxpayers facing complex intercompany arrangements, specialist support from a firm experienced in both audit and tax is essential.

FAQ about Ramirez Enríquez y Asociados

Local expertise and technical support for international advisory firms and multinational groups with related-party transactions, operations or reporting obligations in Peru.

Transfer Pricing Compliance

  • Local File
  • Master File
  • CbCR and Notifications
  • Transfer Pricing Documentation

2. Transfer Pricing Advisory & Planning

  • Transfer Pricing Planning and Strategy
  • Intercompany Pricing Policies
  • Prospective Transfer Pricing Analyses
  • Cross-Border Transaction Planning
  • Business Restructuring

3. Economic & Financial Analysis

  • Benchmarking Studies
  • FAR Analysis
  • Profitability and Margin Analyses
  • Financial Transactions
  • Intercompany Financing
  • Valuation and Economic Analyses
  • Intangibles and Royalties

4. Transfer Pricing Controversy & Risk

  • Transfer Pricing Health Checks
  • Risk Assessments
  • SUNAT Audit Support
  • Tax Authority Assistance
  • Transfer Pricing Dispute Resolution

An audit-driven, multidisciplinary approach that blends chartered accountancy with specialised tax capabilities, aligning accounting evidence with commercial narratives to justify transfer prices. Our multidisciplinary team, comprised of economists and accountants, provides continuous support throughout the engagement, assisting in the collection, validation and processing of information, as well as addressing any questions or issues that may arise. Additionally, we are connected to an international accounting network, enabling seamless cross-border support and coordinated expertise across multiple jurisdictions.

Led by senior Chartered Public Accountants and consultants, notably Socia Principal Ana María Dávila; partners and managers hold university degrees, postgraduate training, and professional specialisations in audit and taxation.

Peruvian subsidiaries of multinationals, export/import traders, family groups with cross-border arrangements, and local companies with related-party services or financing benefit from their audit-aligned transfer-pricing guidance.

  1. Local File compliance
    Failure to file the Transfer Pricing Local File return, or filing incomplete or inaccurate information, may result in a penalty of 0.6% of the taxpayer’s net income, subject to the applicable minimum and maximum limits under the Peruvian Tax Code. Local File filing requirements generally apply to taxpayers whose accrued income exceeds 2,300 UIT, together with the applicable transaction thresholds.
  2. Transfer Pricing adjustments
    SUNAT may adjust the value of controlled transactions when the agreed terms do not comply with the arm’s length principle and the applicable conditions for a Peruvian tax adjustment are met. Such adjustments may increase the Peruvian taxable income and corporate income tax liability.
  3. Transfer Pricing documentation
    Taxpayers must maintain supporting documentation for their controlled transactions, including the information and analysis required under the Peruvian Transfer Pricing rules. Failure to provide documentation requested by SUNAT may result in additional penalties.
  4. Audit and information requests
    SUNAT may request detailed supporting information during a Transfer Pricing audit, including the economic rationale of transactions, comparability analysis, costs, allocation keys, profit margins and other documentation supporting the pricing methodology.

They use econometric benchmarking, transactional forensics and narrative support tying prices to functions, assets and risks; emphasize documentation quality and proper method selection; provide representation in tax audits, injunctions and administrative appeals, including matters before the Tribunal Fiscal.

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