On 23 April 2019, the Peru tax authority (SUNAT) published Report No. 033-2019-SUNAT/7T0000 concerning the application of Peru's thin capitalization rules, which include a restriction on the deduction of interest on loans where a debt-equity ratio of 3:1 is exceeded. The report addresses the question of whether interest on a loan received from a related party by an entity resident in Peru will be subject to the thin cap rules if the funds are used for the realization of investments that will generate income from a foreign source. In this respect, the report notes that the 3:1 thin cap rule...