Overview
- Sunat expanded its Catálogo de Esquemas de Alto Riesgo Fiscal by 11 new modalities, bringing the total to 35 and making the update public to warn taxpayers and guide enforcement.
- The new entries cover tactics used across sectors, including retailers that control cooperatives to channel interest income, universities that build campuses through linked firms then record high rent payments, disguised loans and leveraged buyouts.
- Sunat reported aggregate indicators without naming firms: roughly 40 financial entities and about S/31 million in credits tied to cooperative schemes, and 1,788 contributors reporting around S/4,500 million in rents to related parties.
- The administration said these structures show common red flags such as lack of economic substance, façade or interposed companies, unusual intra‑group pricing and use of tax‑favored vehicles, any of which could trigger assessments, transfer‑pricing adjustments or sanctions under Norma XVI.
- The catalog began in 2020 with five schemes and is modeled on similar tools used by tax authorities in Chile, the UK and Ecuador; Sunat presents v4.0 as both a preventive alert for taxpayers and the basis for targeted fiscal reviews going forward.