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Peruvian tax authorities address merger of nonresident entities with one entity having a PE in Peru

15 October 2020

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Tax Alerts, Legislation & Policy, Na...

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Peru

On 6 October 2020, the Peruvian tax authorities published Public Ruling 061-2020-SUNAT/7T0000, addressing the merger of two nonresident entities when the absorbed entity has a permanent establishment (PE) in Peru.The Peruvian tax authorities ruled the merger will have the following tax consequences in Peru:The PE of the absorbed entity will not have to obtain a new Tax ID.The merger of the two nonresident entities will not have tax effects for the PE in Peru.The absorbed entity will be taxed in Peru on the income from the transfer of the PE because the income qualifies as Peruvian-sourced income._____________________________________________________________________________________________________________For additional information with respect...