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Peruvian Tax Authority establishes guidelines for permanent establishments

31 January 2022

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Tax Alerts, Legislation & Policy, Na...

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Peru

The guidelines establish when a permanent establishment is triggered and when tangible and intangible assets are subject to tax.In Ruling 111-2021-SUNAT/7T0000 (the Ruling), the Peruvian Tax Authority established guidelines for permanent establishments (PEs).Under Legislative Decree 1424, a PE may be created when a nonresident renders services in Peruvian territory for the same project or a related project for more than 183 days in a 12-month period. Under the Ruling, a PE for services will be triggered if the 183-day period is completed after 1 January 2019 (effective date of Legislative Decree 1424), even if the calculation of time started before...