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Peru Clarifies Taxation of the Indirect Transfer of Shares in Peruvian Companies

11 June 2019

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Approved Changes

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Peru

On 4 June 2019, the Peru tax authority (SUNAT) published Report No. 046-2019-SUNAT/7T0000 concerning the determination of the market value of shares in relation to the rules for the taxation of the indirect transfers of shares in Peruvian entities. Subject to certain conditions, a transfer is generally considered an indirect transfer of a Peruvian entity's shares, and subject to tax, if: In any of the twelve months prior to the transfer, the market value of the shares or participation in the Peruvian entity is equal to 50% or more of the total market value of the shares of the non-resident...