Peru Clarifies Taxation of Indirect Transfers through a Contribution of Shares to a New Non-Resident Company

The Peru tax authority (SUNAT) has published Report No, 024-2018-SUNAT/7T0000 concerning the taxation of the indirect transfer (alienation) of shares in a Peruvian company through the transfer of shares of a non-resident holding company. The report covers a case involving a non-resident holding company that holds a majority of the shares of a Peruvian company, where the shares in that holding company were contributed as part of the establishment of a new non-resident company that is part of …