The Peruvian Tax Authority has established that a reverse merger between nonresident entities whereby the absorbing entity is the direct shareholder of a Peruvian entity triggers an indirect transfer of Peruvian shares.On 5 December 2022, the Peruvian Tax Authority published Ruling 000087-2022 confirming that a reverse merger performed between nonresident entities where the absorbing entity is a direct shareholder of a Peruvian entity triggers an indirect transfer of Peruvian shares.BackgroundA reverse merger is performed between a foreign company (Company A), which is absorbed by its foreign subsidiary (Company B), with Company A being owned by another foreign entity (Company C)...