A new ruling from the Peruvian Tax Authority interprets a provision of the Peru-Chile Double Tax Treaty pertaining to capital gains tax treatment of certain direct and indirect transfers.The new interpretation repeals a 2021 ruling. The Peruvian Tax Authority issued a ruling at the end of 2023 establishing that, in applying Article 21 of the Peru-Chile Double Tax Treaty (DTT), capital gains obtained by a Chilean resident from an indirect transfer of Peruvian shares through a direct transfer of Chilean shares could also be taxed in Peru.BackgroundPeruvian income tax law sources the indirect transfer of Peruvian shares as taxable. An indirect...