Low-Value Intra-Group Services: Clear and Simple

In the world of Transfer Pricing, one of the most confusing and widely misunderstood concepts is the well-known topic of low-value intra-group services.

Let’s explain it in a clear and simple way:

A low-value service is one that can be provided by the parent company, a service center, or any other group member, as long as it meets the following conditions:

✅ It has a supportive nature.
✅ It is not part of the core business — that is, it does not directly generate profits or influence strategic decisions.
✅ It does not use or create unique or valuable intangibles.
✅ It does not assume or control significant risks.

💡 Important note:
Just because a service does not qualify as low value doesn’t mean it automatically generates large margins or profits. It simply means it doesn't meet the criteria listed above.

📌 How is this regulated in Peru?

When it comes to margins, in Peru, low-value intra-group services cannot exceed 5% of costs or expenses.

🔧 Typical examples of low-value services:

• Administrative support

• Basic accounting

• Standard HR services

• IT system maintenance

If your company performs transactions with related parties and provides (or receives) this type of service, HLB Peru has the expertise to help you identify and properly document the associated costs and expenses across the region—complying with SUNAT’s requirements and international best practices.