Tax News Update    Email this document    Print this document  

October 14, 2020
2020-2471

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

If two nonresident entities merge and the absorbed entity has a permanent establishment in Peru, the absorbed entity will have to pay tax on the income from the transfer of the permanent establishment. The tax authorities address other tax consequences of the merger in the ruling.

On October 6, 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.

———————————————

Contact Information
For additional information concerning this Alert, please contact:
 
Ernst & Young Asesores S.C.R.L, Lima
   • Roberto Cores (roberto.cores@pe.ey.com)
   • Ramón Bueno-Tizón (ramon.bueno-tizon@pe.ey.com)
Latin American Business Center, New York
   • Ana Mingramm (ana.mingramm@ey.com)
   • Enrique Perez Grovas (enrique.perezgrovas@ey.com)
   • Pablo Wejcman (pablo.wejcman@ey.com)
 

The information contained herein is general in nature and is not intended, and should not be construed, as legal, accounting or tax advice or opinion provided by Ernst & Young LLP to the reader. The reader also is cautioned that this material may not be applicable to, or suitable for, the reader's specific circumstances or needs, and may require consideration of non-tax and other tax factors if any action is to be contemplated. The reader should contact his or her Ernst & Young LLP or other tax professional prior to taking any action based upon this information. Ernst & Young LLP assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect the information contained herein.

 

Copyright © 1996 – 2024, Ernst & Young LLP

 

All rights reserved. No part of this document may be reproduced, retransmitted or otherwise redistributed in any form or by any means, electronic or mechanical, including by photocopying, facsimile transmission, recording, rekeying, or using any information storage and retrieval system, without written permission from Ernst & Young LLP.

 

EY US Tax News Update Master Agreement | EY Privacy Statement