The Peruvian Tax Court recently published Resolution 08835-12-2012, establishing that the migration of an entity from Panama to Canada which in turn owns the shares of a Peruvian company, does not prevent the application of the benefits of the Peru-Canada Double Tax Treaty (DTT) for capital gains, upon the subsequent sale of the Peruvian shares.BackgroundThe Peruvian Tax Court analyzed the case of a legal entity which was a shareholder of a Peruvian entity that migrated from Panama to Canada in 2013 and once redomiciled in Canada, obtained capital gains from the transfer of Peruvian shares carried out in July 2014.As...