Entities that qualify as a conduit company will not qualify as beneficial owner under the Peru-Chile income tax treaty, so payments they receive will be subject to a higher rate of withholding tax under Peruvian tax law.The Peruvian Tax Court recently published Resolution 03306-9-2020, establishing guidelines for entities to qualify as beneficial owners, which are entitled to benefits under the Peru-Chile double tax treaty.BackgroundA Peruvian taxpayer applied a 15% withholding tax (WHT) rate to lease payments for telecommunications equipment provided by a Chilean entity. The Tax Court analyzed whether the company resident in Chile qualifies as a beneficial owner that...