Our Expert in Peru
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Ramírez Enríquez y Asociados is proud to be welcomed as an Exclusive Member of Global Law Experts. This appointment reinforces the firm’s long standing presence in Peru and its ability to deliver integrated advisory support across tax, audit, and transfer pricing for both domestic companies and multinational groups. The practice is built on disciplined technical work, high quality documentation, and the capability to support clients on matters that require a cross border perspective.
In Peru, transfer pricing involves much more than providing isolated tax guidance. It demands a careful balance of accounting evidence, economic analysis, and a strong understanding of how intercompany pricing is assessed by the tax authorities. Ramírez Enríquez y Asociados has structured its transfer pricing offering around these core requirements. The firm is known for assisting clients with compliance and documentation as well as for handling controversy and dispute related matters. It also brings together the strengths of chartered accountancy with specialised tax expertise, which is particularly important in a field where financial records, transaction flows, and tax positions must align consistently.
The firm’s professional profile is anchored by a senior team of Chartered Public Accountants and experienced consultants. Leadership includes Ana María Dávila as Socia Principal, supported by partners and managers with university education, postgraduate training, and focused professional specialisations in audit and taxation. For multinational groups and Peruvian businesses alike, this background matters because transfer pricing is not only a legal requirement. It is also an operational and evidentiary exercise. Clients benefit from a team that can review the numbers, challenge the underlying assumptions, and convert commercial activity into defensible documentation.
Additionally, Ramírez Enríquez y Asociados is a member of LEA Global, one of the world’s leading international associations of independent accounting, tax, audit, and advisory firms. Through this network, the firm has access to a broad pool of international expertise, technical resources, and local market knowledge across numerous jurisdictions. This enables the firm to support clients with cross-border transactions, international transfer pricing matters, and multinational compliance requirements, while maintaining the responsiveness and personalized service of a local advisory practice.
This combination of local expertise, international reach, technical depth, and professional maturity is one of the reasons Ramírez Enríquez y Asociados aligns with the standards expected by Global Law Experts, providing clients with a structured and practical approach to addressing complex tax and transfer pricing challenges.
Ramírez Enríquez y Asociados covers the full range of transfer pricing issues commonly encountered under the Peruvian tax framework.
The firm assists with the preparation of the Local File (Reporte Local), Master File (Reporte Maestro), and Country-by-Country Report (Reporte País por País), as well as transactional pricing analyses, intercompany service policies, EPT filings, documentation strategies, and benchmarking studies designed to demonstrate compliance with the arm’s length principle. These services are delivered with a strong focus on ensuring that clients meet the filing deadlines established by the Peruvian Tax Administration and maintain robust supporting documentation for transfer pricing purposes.
In particular, the Local File is generally due in June of each year, although the filing corresponding to fiscal year 2025, to be submitted in 2026, has been exceptionally extended to November 2026. The Master File and Country-by-Country Report are generally due in October of each year, subject to the requirements and thresholds established under Peruvian transfer pricing regulations. Through continuous support in gathering, reviewing, and processing information, as well as resolving questions that arise throughout the process, the firm helps clients comply with their reporting obligations in a timely and efficient manner, reducing transfer pricing risks and strengthening their audit defense position.
This is a comprehensive service model rather than a narrow compliance function. It is intended for clients who need support at the planning stage, throughout annual filing and documentation cycles, and when their pricing positions must be defended before the tax administration.
That comprehensive approach is especially valuable in Peru, where transfer pricing compliance depends on close coordination between tax law and administrative practice. The firm’s source materials emphasise that Peru’s transfer pricing regime is grounded in the Income Tax Law and SUNAT administrative rules, with annual informative declarations and technical studies potentially required depending on the transactions involved. The practice also reflects the relevance of OECD aligned methods and specific requirements for intragroup services, including the benefit test linked to deductibility. In such an environment, generic tax advice is not enough. Clients need a team that can connect technical documentation with commercial reality and ensure that pricing positions are supported in a way that can withstand scrutiny.
One of the firm’s distinguishing strengths is its audit driven approach. Rather than treating transfer pricing as a purely theoretical or legal matter, Ramírez Enríquez y Asociados applies audit discipline and accounting based evidence to support tax strategy. This can be particularly useful when SUNAT questions intercompany pricing or when the benefit test is challenged in relation to intragroup services. Aligning accounting records, business narratives, and transfer pricing methodology is a hallmark of effective advisory work in this area. It also reflects the integrated way Global Law Experts approaches its Exclusive Member model, seeking firms that deliver precision, structure, and practical relevance.
The firm’s capabilities extend beyond documentation into the controversy side of transfer pricing. The source article highlights that Ramírez Enríquez y Asociados helps clients reduce fiscal exposure through appropriate method selection, proactive adjustments, and robust documentation. It also supports clients during tax audits, injunction related proceedings, and administrative appeals, where the strength of the underlying technical file can make a real difference. In Peru, weak documentation or non compliant practices can result in assessments, penalties, and prolonged administrative reviews. The firm is positioned to help clients respond to these risks with econometric benchmarking, transactional forensics, and clear narrative support that links pricing to functions, assets, and risks.
Ramírez Enríquez y Asociados also demonstrates engagement with evolving tax developments. The source materials describe an active presence through publications and client alerts, including commentary on Tribunal Fiscal decisions and tax criteria that can affect prorrata and deductible expense treatment. The firm also participates in regional conferences and network events, broadening its exposure to comparative transfer pricing practices and case law. For clients, this means the firm is not simply applying a static template. It stays focused on the realities that shape how compliance requirements and transfer pricing disputes develop over time. In a domain where administrative criteria and judicial interpretation influence outcomes, this active technical involvement strengthens credibility.
Sector experience further strengthens the firm’s transfer pricing practice in Peru. The firm advises a mix of private and public interest entities across capital intensive industries, export and import operations, agribusiness, and financial services. These are exactly the types of sectors where transfer pricing can become more complex due to cross border flows, multi layer supply chains, and transactions involving related parties. Businesses in these areas need advisers who understand both the technical tax rules and the commercial pressures that drive pricing decisions. The firm’s multidisciplinary platform supports this need by combining audit, tax, outsourcing, and consulting capabilities under one coordinated model.
This expertise is particularly relevant for Peruvian subsidiaries of multinational enterprises, family groups with cross border arrangements, and local companies that engage in related party services or financing. As the source article notes, these are the client categories most likely to benefit from the firm’s support. For these businesses, transfer pricing is not a one time task. It is an ongoing discipline involving documentation preparation, analysis, review, and sometimes dispute management. Ramírez Enríquez y Asociados is presented as a firm that can support the full cycle, from initial compliance work to the defence of pricing positions.
This profile is highly consistent with Global Law Experts selection expectations. An Exclusive Member is expected to demonstrate recognised capability in its field, show clear client focus, and meet a level of professional sophistication that works well for an international audience. Ramírez Enríquez y Asociados meets these requirements through its integrated audit and tax model, its experience with transfer pricing documentation and controversy matters, its membership within an international accounting network, and its direct engagement with Peru’s compliance landscape. The firm’s work is technically rigorous, yet grounded in business context, which is essential in transfer pricing matters where legal structure and commercial reality must be reconciled.
The membership also highlights the firm’s ability to support cross border matters. The source material indicates that the firm’s international accounting network strengthens its capacity to handle complex intragroup arrangements and multinational documentation requirements. Transfer pricing rarely stays within national boundaries, and the ability to coordinate analysis across jurisdictions, align documentation expectations, and offer clients a broader professional perspective is a significant advantage. This further establishes Ramírez Enríquez y Asociados as a reliable adviser for clients operating in Peru and beyond.
Finally, the firm’s public activity reflects a sustained commitment to tax and transfer pricing rather than a temporary interest. Ongoing commentary on rulings and administrative guidance, together with reported participation in conferences and network events, signals an active and informed practice. Clients seeking a transfer pricing adviser in Peru will find the exact combination they need: technical depth, current awareness, and the ability to translate complex rules into practical support.
Global Law Experts is therefore pleased to welcome Ramírez Enríquez y Asociados as an Exclusive Member. The firm’s Peru focused transfer pricing practice brings together audit rigor, tax strategy, documentation discipline, and practical controversy support in a way that matches the demands of modern cross border business. For companies navigating SUNAT requirements, intragroup pricing questions, and the need for credible evidence, Ramírez Enríquez y Asociados offers a multidisciplinary approach that is both technically sound and commercially relevant.
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