Peru: Changes for Comprobantes de Pago

On December 22nd, 2018, the Peruvian tax authority SUNAT published Resolution No. 295-2018 which outlines changes to the current Comprobantes de Pago system.


Exemption from Comprobantes de Pago

The resolution includes certain exceptions for submitting the Combrobantes de Pago documents in cases where taxpayers could not create the documents for reasons outside of their reach. Taxpayers who could not submit the documents for technical reasons are therefore exempt from submitting “leyendas” and the “frase emisor electrónico”.


In order be viable for such exemption, the following criteria have to be fulfilled:

  • The print date has to be prior to September 1st, 2018
  • The legal norms for comprobantes de pago and withholding taxes (comprobantes de retencion oder percepcion), effective sind August 31st, 2018, have to be abided by


For some designated taxpayers that have submitted their documents until December 31st, 2018, the another exception applies. If due to technical difficulties of the virtual document 816 no print authorization could be requested, the affected companies can communicate this situation to the SUNAT until January 31st, 2019. The communication has to be submitted in written form and signed by a RUC accredited legal representative of a taxpayer service center. SUNAT will also publish a list of the taxpayers that have submitted such communication.



SUNAT has also published another Resolution No. 312-2018 on December 31st, 2018 which frees certain institutions of the requirement to

submit Comprobantes de Pago until a determined deadline:


  • Companies of the financial system until June 30th, 2019
  • All other companies that are named in specific parts of Resolution No. 318-2017 until December 31st, 2019


Additional Changes

The resolution contains numerous other news and changes including:

  • Designation of health institutions as electronic issuers from January 1st, 2020
  • Introduction of activities that are exempt from SPOT:
    • Companies within the finance and insurance sector underlying the control of SBS and AFP which issue electronic invoices
    • The catholic church for her renting activities
  • Retraction of categorization of PERUPETRO S.A. as electronic issuer
  • Changes to Comprobantes de Pago for companies of the financial system as outlined in paragraph 1.9 of article 7 of the Decree on Comprobantes de Pago


These regulatory changes could affect your business with view to customizing or support of your ERP/SAP system. Please contact us to learn about possible necessary reactions to the changes – we are happy to assist you!