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Peru's New Interest Deduction Restriction in Force from 2021

19 March 2021

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Approved Changes

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Peru

As previously reported, Legislative Decree No. 1424 of 2018 introduced new thin capitalization and interest deduction restriction rules in Peru. With respect to thin capitalization, the Decree provided that from 1 January 2019 to 31 December 2020, the thin capitalization rules (3:1 debt-equity) applied in relation to both related and unrelated party debt (previously, just related). From 1 January 2021, the thin capitalization rules are replaced, as per the Decree, with a general restriction on the deduction of net interest expense exceeding 30% of EBITDA of the previous year, with excess interest expense carried forward up to four years. An...