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Peruvian Tax Authority establishes guidelines on scope of applying nondiscrimination clause of the Double Tax Treaties signed by Peru

28 July 2023

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Peru

A Tax Authority ruling has distinguished between Double Tax Treaties (DTTs) that Peru has signed with various countries.In some cases, additional language in the DTTs states that the nondiscrimination clause applies to nationals of a Contracting State only if they are also residents of that State.And in other cases, where the additional language is absent, the nondiscrimination clause in the DTTs applies even if nationals of a Contracting State are not residents of that State.In Ruling 000087—2023, published on 11 July 2023, the Peruvian Tax Authority determined that the nondiscrimination clause included in the Double Tax Treaties (DTTs) that Peru...