The Supreme Court of Peru on 15 May 2024 issued its decision in a case concerning entitlement to the benefits of the Chile-Peru tax treaty (Sentencia en Casación N° 34212-2023). The case concerned the withholding tax applicable in Peru on the payment of Peruvian-source royalties to a Chilean entity, Arrendadora Móvil Sociedad Anónima. The payer withheld tax at the reduced rate of 15% provided for under the Chile-Peru tax treaty, whilst the Peruvian tax authorities took the position that tax had to be withheld at the higher domestic rate of 30% because the Chilean recipient does not qualify as the...