Bibliographic citations
Castro, H., (2020). Evaluation of the application of the safe harbour on low value-adding services in Peru. Is the safe harbour on low value-adding services suitable for a developing country such as Peru? [Tilburg University]. https://renati.sunedu.gob.pe/handle/sunedu/3006929
Castro, H., Evaluation of the application of the safe harbour on low value-adding services in Peru. Is the safe harbour on low value-adding services suitable for a developing country such as Peru? []. NL: Tilburg University; 2020. https://renati.sunedu.gob.pe/handle/sunedu/3006929
@mastersthesis{renati/2829,
title = "Evaluation of the application of the safe harbour on low value-adding services in Peru. Is the safe harbour on low value-adding services suitable for a developing country such as Peru?",
author = "Castro Zapata, Héctor Manuel",
publisher = "Tilburg University",
year = "2020"
}
For the purpose of this thesis, the case of Peru and its recent implementation in national legislation of the simplified approach on LVAS are evaluated. The incorporation of this norm is in line with other adaptations of the BEPS plan and with the country's objective of being part of the OECD in 2021. The approach has been mainly criticized because, in the way it has been enacted, it does not follow the model suggested in Action 10. The safe harbour does not fulfil its nature of being optional3, limiting the actions of companies. Likewise, it fails to meet its objective of reducing the documentary burden of taxpayers, since the Peruvian tax administration does not refrain from reviewing the benefits test, even if the documentary requirements are met4. In addition, it still requires the benchmarking study to support the mark-up chosen. Finally, the studies carried out so far question that a deductibility rule for expenses has been included in the transfer pricing article of the Income Tax Law, when this is mainly related to the valuation of transactions5. This inclusion might generate uncertainty at the time of a possible audit. This research analyses if this scheme is suitable for Peru, under the benchmark of the two main objectives of the safe-harbour: cost reduction and certainty. It follows the same line of the mentioned studies, and delves into aspects of international taxation and the current Peruvian tax system.
File | Description | Size | Format | |
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CastroZapataHM.pdf | Tesis | 831.42 kB | Adobe PDF | View/Open |
Autorizacion.pdf Restricted Access | Autorización del registro | 688.11 kB | Adobe PDF | View/Open Request a copy |
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