The tax authority’s Resolution 377-2013/SUNAT, published in the Official Gazette on 29 December 2013.Accordance with the Resolution 377/2013, intention to negotiate an APA should be expressed in writing to SUNAT which must reply within 15 days. Preliminary meetings may be held or alternatively the final proposal for an APA may be sent directly to SUNAT. SUNAT has 24 months to accept or reject the APA proposal but may extend this period by a further 12 months. The APA may cover the year of acceptance and three further years. The taxpayer may exit the preliminary meetings by giving notice in writing. SUNAT may take the decision to reject the application at any time within the 24 month time limit.
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