On 28 September 2020, the Peruvian Tax Court held (Resolution 5934-5-2019) that a nonresident must provide a Peruvian payor with a Certificate of Residency when withholding is triggered for the payor to apply double tax treaty (DTT) benefits when calculating the withholding tax on the transaction.BackgroundAccording to Peruvian tax legislation, to invoke the benefits of a DTT, nonresidents must give the Peruvian payor a Certificate of Residency that meets the following requirements:Establishes that the nonresident is resident of a country having a DTT in force with Peru and, therefore, is subject to tax in that country for the period established...