October 14, 2020
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: