The Peruvian Tax Court recently confirmed, in Resolution 02171-12-2023, that Peruvian branches of an entity that is resident in an Andean Community member country are considered Peru-resident entities. Further, the court held that the deemed dividends distributed to the branch's parent entity should be subject to withholding exclusively in Peru under article 11 of the Decision 578, a Multilateral Agreement to avoid double taxation in the Andean Community (Peru, Ecuador, Colombia and Bolivia). BackgroundUnder Peruvian Income Tax Law, Peruvian branches of nonresident entities are considered independent from their parent company. Furthermore, the Peruvian Income Tax Law has established a tax...