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Peruvian Tax Authority establishes guidelines for application of new thin capitalization rules

26 May 2021

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Tax Alerts, Legislation & Policy, Na...

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Peru

The new guidelines clarify when the deduction for interest expenses will be limited and how the new thin capitalization rules apply to recently incorporated companies and companies in the preoperative stages.The Peruvian Tax Authority established guidelines (Ruling 015-2021-SUNAT/7T0000) for the application of the new thin capitalization rules for companies with interest expenses during their preoperative stage or companies that recently incorporated.BackgroundThe new thin capitalization rules, effective since 1 January 2021, limit the “net interest” deduction for corporate income tax purposes to the extent the “net interest” exceeds 30% of EBITDA (i.e., net income after offsetting losses plus net interest, depreciation...