The saldo a favor del exportador (the exporter's tax credit balance) is liquidity that has already left the company's cash and that the law recognizes as recoverable. Even so, between the application and the disbursement there are usually months of document requests that, in most cases, could have been anticipated. These are the five mistakes that most often drag out the procedure.
First: failing to control the limit for the period
The saldo a favor del exportador becomes Saldo a Favor Materia del Beneficio (the portion of the balance eligible for refund) subject to a ceiling: it may not exceed a percentage equivalent to the IGV rate (the Peruvian VAT), including the Impuesto de Promoción Municipal (the municipal promotion tax), applied to the exports carried out in the period. Anything above that limit is not lost, but it is not refundable that month: it carries forward as exporter's tax credit balance to the following months (article 4 of the Reglamento de Notas de Crédito Negociables, the regulations on negotiable credit notes, Decreto Supremo 126-94-EF).
The mistake consists of applying for a refund of the accumulated balance without having run the calculation month by month. The application is challenged, it has to be redone, and the place in line is lost.
Second: confusing the invoice date with the shipment date
The benefit is determined on the basis of the exports shipped during the period. An invoice issued in one month whose goods were shipped in the following month does not count in the month of issue. When transaction volume is high and there are shipments at month end, this difference shifts the limit for the period and throws off the entire calculation.
The way to avoid it is simple and almost nobody applies it: reconcile the sales register monthly against the finalized export customs declarations, before assembling the PDB.
Third: filing the PDB Exportadores without having reconciled it
The PDB Exportadores (the exporters' information return) is the informative filing that supports the application. When the information in the PDB does not match the purchase register, the monthly returns or the electronic books, the tax authority's automated cross check detects it and generates a document request before any analysis of the merits.
It is worth reconciling the same information three times before submitting it: PDB against the purchase register, purchase register against the monthly return, and monthly return against the electronic books filed.
Fourth: supporting the credit with the voucher alone
This is the costliest ground for challenge, because it cannot be resolved with a brief: it is resolved with documentation that should have been generated when the transaction took place.
For the purchases that support the balance, the tax authority assesses whether the transaction is substantiated. That means proving that the good or service existed and was allocated to producing what was exported. A properly issued and recorded voucher is necessary, but not sufficient. It is also advisable to have:
- Traceability of the payment: a banked means of payment, matching amounts and dates, and a bank statement.
- Evidence of performance: dispatch notes, contracts, purchase orders, warehouse receipts, inventory records, service reports.
- A link to the export: that the input or service can be associated with the production process of the goods actually exported.
- Verification of the supplier: the status and standing of its RUC as of the date of the transaction, and reasonable operating capacity to provide what it invoiced.
When the supplier turns out to be challenged, the credit is lost even if the company acted in good faith and paid. That is why reviewing the supplier is a preventive control, not the supplier's problem.
Fifth: failing to anticipate the order of offsetting
Before there is anything to refund, the Saldo a Favor Materia del Beneficio is automatically offset against liabilities for advance payments and for the annual settlement of the Impuesto a la Renta (corporate income tax). If there were no income tax payable, or if a remainder were left, only then does the offsetting reach other tax liabilities that constitute revenue of the Public Treasury, provided the company holds taxpayer status with respect to those taxes.
Many companies file the application without having run this sequence and later discover that a good part of the balance was already committed. The effect on the cash flow projection is not minor.
An underlying recommendation
A preventive audit of the balance, carried out before filing the application, costs a fraction of what it costs to handle a subsequent tax audit, and it changes the starting point: the application is filed with the file already assembled, rather than reacting to document requests.
For exporters filing recurring applications, the difference between an orderly process and an improvised one is measured directly in months of working capital.
This article is for informational purposes only and does not constitute tax advice for a specific case. Rates, ceilings and procedures must be verified as of the date of the transaction.
This is a translation for informational purposes. The Spanish version of this article is the only authoritative one; in case of any discrepancy, the Spanish text prevails.