20220210-IMF-Peru_Technical_Assistance_Report-Tax_Regime_for_Small_Taxpayers_and_Special_Economic_Zones_68页_1mb

Summary: Analysis of Peru's Tax Regime and Special Economic Zones

Small Taxpayers Regime:

• Peru has three simplified tax regimes for micro and small enterprises (MSEs): NRUS (fixed fees for micro-enterprises), RER (1.5% gross income tax), and RMT (progressive tax).
• Existing regimes create arbitrage opportunities due to overlapping thresholds, low tax collection (only 0.6% of GDP from these regimes), and minimal impact on formalization.
• Recommendations:
  • Merge RER and RMT into an intermediate regime based on cash flow (tax rate: 29.5%, same as the general regime), with a threshold at 150 UIT.
    -Keep NRUS unchanged for now, updating fees and allowing semi-annual/yearly payments with discounts (funds $74 million increase).
    -Eliminate profit-sharing thresholds that incentivize informality.

Special Economic Zones (SEZs):

• SEZs (Tacna FTZ, Ilo, Paita, Mataraní SDZs) offer full income tax exemptions and indirect tax advantages.
• SEZs have failed to promote regional development or attract significant investment (e.g., $47 million exports in 2018).
• Recommendations:
  -Eliminate full income tax exemptions for SEZs to comply with OECD’s BEPS standards and avoid WTO export subsidy violations.
  -Restrict SEZs to regional development zones (disadvantaged areas) and link tax benefits to employment/investment targets.
  -Standardize SEZ regulations across current zones into a single framework (excluding tax terms) and create SEZs only via law (not framework decrees).

Key Concerns:

• High informality (60-70% of economy) driven by multiple factors beyond taxes (labor regulations, education).
• SEZs risk unfair competition and erosion of the national tax base due to income tax exemptions.
• Digital tools (electronic invoicing, cash flow-based systems) should support implementation.

Overall:

• Tax reforms should focus on simplification and fairness, merging small business regimes and limiting SEZ incentives to targeted regional development.