The legislative decree modifies the tax treatment of silent partnerships. Specifically, the legislative decree establishes that income distributed to the silent partner will be considered dividends and dividends distributed to nonresident silent partners will be considered Peruvian-source income, subject to 5% withholding.On 26 March 2022, Peru’s President enacted Legislative Decree 1541, amending the Income Tax Law to modify the silent partnership rules.Background On 2 April 2021, the Peruvian Tax Court published, in the Official Gazette, Resolution 02398-11-2021, which established that income distributed to a silent partner should be treated as dividends. The Resolution is mandatory, which means the Peruvian tax authority must...