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Peruvian Tax Authority rules merger between nonresident entities triggers indirect transfer of Peruvian shares

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Peru

  • The Peruvian Tax Authority considered whether a merger by absorption between nonresident entities in which the absorbed entity is the indirect shareholder of a Peruvian entity has tax consequences in Peru.
  • The Tax Authority ruled the merger triggers an indirect transfer of Peruvian shares.

In Ruling 000076–2023, published on 13 June 2023, the Peruvian Tax Authority determined that a merger between n…

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