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Peruvian Tax Authority clarifies methodology for determining FMV of listed/unlisted shares in indirect disposal scenario

13 June 2023

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Tax Alerts, Information Reporting, Legis...

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Peru

A Tax Authority ruling in Peru provides guidance on how to determine the fair market value of shares in an indirect transfer of shares between a foreign and a Peruvian entity.This Tax Alert provides background and highlights the new guidance.On 25 May 2023, the Peruvian Tax Authority issued Ruling 64-2023, addressing how to determine the fair market value (FMV) of shares in an indirect transfer scenario if the shares of the nonresident entity are listed on a stock exchange and the shares of the Peruvian company are not listed (or vice versa).BackgroundFor purposes of determining the FMV of the foreign...