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.
For additional information with respect to this Alert, please contact the following:
Ernst & Young Asesores S.C.R.L, Lima
- Roberto Cores
- Ramón Bueno-Tizón
Ernst & Young LLP (United States), Latin American Business Center, New York
- Ana Mingramm
- Enrique Perez Grovas
- Pablo Wejcman
Ernst & Young Abogados, Latin America Business Center, Madrid
- Jaime Vargas
Ernst & Young LLP (United Kingdom), Latin American Business Center, London
- Lourdes Libreros
Ernst & Young Tax Co., Latin American Business Center, Tokyo
- Raul Moreno
