The landscape has changed, and that is already becoming apparent in practice. With the update to the sanctions regime applicable as of 2026, penalties for formal non-compliance in the area of International Operations have taken on significantly greater weight. And this doesn’t only affect large Multinational Groups: it can also impact importing or exporting companies, even when they operate with independent parties.

The General Directorate of Taxation has officially published Resolution MH-DGT-RES-0026-2025, which sets forth the general provisions for submitting the Transfer Pricing Informative Return (TP IR). This regulation aims to enhance tax control over related-party transactions, ensuring they are valued according to the Arm’s Length Principle.

April 30th is the deadline for filing the TP Report, in both physical and digital formats, and the Informative Return on Transactions with Related Parties (Form F.601), corresponding to the fiscal year ending on December 31, 2024.

Next April 30, 2025 is the deadline to file the Informative Return on Related Party Transactions (DIOR) for the fiscal year ending December 31, 2024.

Next April 30th marks the deadline for submitting the Annual Transfer Pricing Informative Return, which, for the first time, must be filed through the new SIISAR platform (Integrated Information System of the Tax Administration Service), implemented in June 2024.

This Resolution issued by the Internal Revenue Service (SII) in March 2025 is based on Art. 41 H of the Income Tax Law, which establishes when a territory or jurisdiction is considered to have a preferential tax regime, determining that the SII will rule, through a resolution, on those territories or jurisdictions that qualify as such.

This Resolution issued by the Internal Revenue Service (SII by its acronym in Spanish, Servicio de Impuestos Internos) in March 2025 nullifies Resolutions Nº 68 of 2013 and Nº 114 of 2022, which had the same purpose. This update is aligned with Tax Compliance Law Nº 21,713 of September 25, 2024.

The General Directorate of Internal Taxes has published a Guidance for the 2025 Fiscal Year, aimed at facilitating compliance with obligations regulated in the Tax Code. The objective is to help identify countries, states, or territories that have preferential tax regimes with low or no taxation.

On January 1st, the reform to the Income Tax Law came into effect, modifying the Transfer Pricing Regime in Peru through Legislative Decrees 1662 and 1663.

With the goal of improving tax collection without increasing taxes, the Tax Administration Service (SAT) has introduced its 2025 Master Plan, aiming to generate 5.3 trillion pesos through a strategy focused on digitalization, streamlining procedures, and combating tax evasion.

Today, February 26, 2025, is the final deadline for submitting public comments on Resolution MH-DGT-RES-000-2025, issued by the General Directorate of Taxation. This resolution provides an opportunity for entities representing general, corporate, or diffuse interests to submit their observations on the proposed guidelines for the submission of the Transfer Pricing Informative Return.

Law Nº 15,079, enacted on December 27, 2024, establishes the Additional Social Contribution on Net Profit (CSLL) as part of Brazil’s effort to align with the Global Anti-Base Erosion Rules (GloBE Rules) under the OECD’s Pillar II Inclusive Framework. This law aims to implement an effective minimum taxation of 15% for multinational groups generating annual revenues of at least 750 million euros, thereby ensuring greater equity and transparency in international taxation.