The Application of International Valuation Standards (IVS) in Peru: Technical and Tax Implications and Their Relationship to BEPS and Transfer Pricing.

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TThe International Valuation Standards (IVS), issued by the International Valuation Standards Council (IVSC), constitute a global technical framework for the preparation of consistent, transparent, and verifiable financial valuations. In Peru, pursuant to Supreme Decree No. 302-2025-EF, published on December 17, 2025, for the application of the “other methods” provided for in paragraph 7) of subsection e) of Article 32-A of the Law, the provisions of the International Valuation Standards in effect as of January 1, 2025, must be followed, to the extent that they do not conflict with the provisions of the Law itself.

This article provides a doctrinal and critical analysis of the scope of the International Valuation Standards (IVS), their degree of adoption in the Peruvian context, their relationship to the OECD Guidelines and the BEPS Project, as well as their potential probative value before SUNAT and the Tax Court.

The research employs a qualitative methodology based on an analysis of normative, doctrinal, and case law sources.

1. Introduction

The growing sophistication of business operations, the internationalization of business models, and the central role of intangible assets in value creation have substantially increased the need for technically robust financial valuations. At the same time, tax authorities, including SUNAT, have raised the standard for technical reviews of economic studies, particularly in the area of transfer pricing.

In this context, the International Valuation Standards (IVS) have established themselves as an international technical standard that provides methodological consistency, traceability of assumptions, and professional rigor (IVSC, 2022). As indicated in Supreme Decree No. 302-2025-EF, their progressive adoption reflects a practical convergence toward international standards of high technical quality, especially when valuations must stand up to audits, expert reviews, or administrative and judicial disputes. 

2. Methodology

This study adopts a qualitative, analytical, and descriptive approach.

The research methods employed include a documentary analysis of international standards (IVS, OECD Guidelines, BEPS reports), Peruvian tax legislation, specialized legal literature, and the administrative case law of the Tax Court.

The purpose is to critically evaluate the relevance and usefulness of the International Valuation Standards (IVS) in the Peruvian context, as well as their potential contribution to the technical strengthening of financial valuations and transfer pricing studies.

3. Theoretical and Conceptual Framework of the International Valuation Standards (IVS)

The International Valuation Standards (IVS) constitute a body of technical standards designed to ensure that valuation work complies with essential principles of professional quality, including methodological consistency, objectivity, transparency regarding the assumptions used, and adequate disclosure of limitations (IVSC, 2025).

Among the standards with the greatest practical relevance are:

  ▪️ IVS 100—Valuation Framework, establishes the general framework for conducting valuations, defining the appraiser’s criteria for accountability, professional competencies, ethical obligations, and the quality control standards applicable to the valuation process.

  ▪️ IVS 101 – Scope of Work, which requires a precise definition of the purpose of the valuation, the intended users, and the minimum requirements.

  ▪️ IVS 102 – Valuation Fundamentals, which covers fundamental concepts such as market value, fair value, and investment value.

  ▪️ IVS 103 – Valuation Approaches: The relevant and appropriate valuation approaches must be considered , relevant and appropriate valuation approaches must be considered, applying one or more as appropriate to the basis of valuation.

The main approaches are:

      – Market

      – Revenue

      – Costs.

▪️ IVS 104—Data and Inputs— stipulates that the valuation must incorporate objective information along with the necessary assumptions and adjustments, prioritizing observable market data and ensuring that the data and assumptions used are adequately documented.

   ▪️ IVS 105—Valuation Models, addresses the selection and use of models for the full or partial quantitative implementation of a valuation method, ensuring that they are suitable for their intended use, consistent, and tested to guarantee their correct application.

  ▪️ IVS 106—Documentation and Reporting— establishes the requirements for documentation and reporting, ensuring transparency and clarity in the valuation. The information must be recorded on paper, in electronic files, or on other recording media.

This conceptual framework is fully compatible with the technical requirements of complex valuations in demanding regulatory and tax environments.

4. Integration of the International Valuation Standards (IVS) with the OECD Guidelines and the BEPS Project.

Peru’s transfer pricing regulations, set forth in Article 32-A of the Income Tax Law, are aligned with the OECD Guidelines (OECD, 2022). As a result of the BEPS Project—particularly through Actions 8, 9, and 10—the substantive approach to economic value creation has been strengthened, prioritizing alignment between profits and DEMPE functions with respect to intangibles (OECD, 2015).

This new paradigm requires greater technical sophistication in economic valuation, especially with regard to unique and valuable intangible assets. In this regard, the International Valuation Standards (IVS) provide specialized methodological support for the application of advanced techniques such as discounted cash flow models, the royalty relief method, and the income, market, and cost approaches, as well as hybrid methodologies and scenario analysis.

Consequently, it can be argued that the International Valuation Standards (IVS) do not compete with the OECD Guidelines, but rather serve as a complementary technical framework that strengthens the methodological quality of the valuations required under the arm’s-length principle.

5. Practical Application of the International Valuation Standards (IVS) in the Peruvian Context

5.1 Specialized Professional Internship

In the Peruvian professional sector, leading firms in auditing, financial consulting, investment banking, and economic appraisal have been progressively adopting the International Valuation Standards (IVS) as the technical standard for business and financial valuation work.

This practice is driven by the need to meet international standards required by investors, regulators, and courts, rather than by an explicit regulatory obligation.

5.2 Convergence with IFRS

The mandatory application of International Financial Reporting Standards (IFRS) in Peru has indirectly driven the adoption of techniques aligned with International Valuation Standards (IVS).

In particular, IFRS 13 requires fair value measurement methodologies that, in professional practice, are typically developed based on approaches recognized by the International Valuation Standards (IVS) (IFRS Foundation 2025).

5.3 Evidentiary Value in Administrative and Judicial Proceedings

The International Valuation Standards (IVS) have recently been adopted in Peru (through Supreme Decree No. 302–2025-EF) for the application of “other methods” specified in Article 32-A of the Income Tax Law; their use as a technical standard significantly strengthens the evidentiary value of valuation reports.

In tax litigation proceedings, methodological quality, the consistency of the assumptions, and the traceability of the calculations are decisive factors in the evaluation of expert evidence—

6. Peruvian administrative case law and the requirement for technical justification.

The Court’s case law has consistently held that expert reports and economic studies must be duly supported by objective technical criteria, ruling out assessments that are merely estimative or insufficiently substantiated.

Resolutions such as RTF No. 06856-1-2024 and RTF No. 02334-5-2022 have emphasized the need for reports to clearly disclose the methodology used, the assumptions made, and the economic reasonableness of the results.

Although these rulings do not expressly require the application of the International Valuation Standards (IVS), the evidentiary standards developed by the Tax Court are broadly consistent with the underlying principles of these standards, particularly with regard to methodological transparency, professional diligence, and the traceability of the information used.

7. Technical and Strategic Advantages of Applying the International Valuation Standards (IVS) in Peru

From a technical and strategic perspective, the application of the International Valuation Standards (IVS) offers specific advantages:

      – Improves the quality of valuation reports.

      – Improves its internal consistency.

      – Enhances your credibility with SUNAT and other specialized users

      – Reduces the risk of methodological findings during audit procedures.

In transfer pricing contexts involving intangibles, the combined application of the OECD Guidelines, the BEPS approach, and the International Valuation Standards (IVS) constitutes one of the most robust frameworks available in contemporary professional practice.

8. Challenges to Its Consolidation in Peru

Despite its technical usefulness, significant challenges remain:

      – The lack of explicit legal recognition.

      – The limited availability of specialized training in advanced financial valuation.

      – Methodological heterogeneity among professionals.

      – The lack of explicit references to valuation standards in administrative case law.

Overcoming these limitations requires joint efforts by academia, the professional community, and regulatory agencies.

9. Conclusions

The International Valuation Standards (IVS) constitute a high-quality technical standard whose practical relevance in Peru is becoming increasingly evident, particularly in the areas of intangible asset valuation and transfer pricing.

Its alignment with the OECD Guidelines and the substantive approach of the BEPS Project makes it possible to develop economic analyses that are more robust and defensible before the tax authorities.

Although not mandatory from a regulatory standpoint, the International Valuation Standards (IVS) are currently an indispensable strategic tool for raising the technical standard of financial valuation in the country.