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15 October 2020

Peruvian tax authorities address merger of nonresident entities with one entity having a PE in Peru

On 6 October 2020, the Peruvian tax authorities published Public Ruling 061-2020-SUNAT/7T0000, addressing the merger of two nonresident entities when the absorbed entity has a permanent establishment (PE) in Peru.

The Peruvian tax authorities ruled the merger will have the following tax consequences in Peru:

  • The PE of the absorbed entity will not have to obtain a new Tax ID.
  • The merger of the two nonresident entities will not have tax effects for the PE in Peru.
  • The absorbed entity will be taxed in Peru on the income from the transfer of the PE because the income qualifies as Peruvian-sourced income.

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For additional information with respect to this Alert, please contact the following:

Ernst & Young Asesores S.C.R.L, Lima
Ernst & Young LLP (United States), Latin American Business Center, New York
Ernst & Young Abogados, Latin America Business Center, Madrid
Ernst & Young LLP (United Kingdom), Latin American Business Center, London
Ernst & Young Tax Co., Latin American Business Center, Tokyo

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Document ID: 2020-6333

 
 

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