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Peru establishes gains from indirect transfer of Peruvian shares will be taxed only in Chile under Peru-Chile DTT

01 March 2021

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Tax Alerts, National/Federal Taxation, T...

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Chile, Peru

The ruling clarifies where capital gains derived from the indirect transfer of Peruvian shares through a transfer of Chilean shares by a Chilean resident will be taxed. The ruling is good news for Chilean residents that own Peruvian shares, as their capital gains will be taxed only in Chile if they indirectly transfer the Peruvian shares.In guidance (Ruling No. 001-2021-SUNAT/7T0000), the Peruvian tax authorities established that capital gains obtained by a Chilean resident from the indirect transfer of Peruvian shares through the transfer of Chilean shares will be taxed only in Chile under the Peru-Chile double tax treaty (DTT).Background Peruvian...