Peru Publishes Legislative Decrees on Implementation of GAAR, New Interest Restriction Rules, Definition of PE, and Other Changes

Peru has published Legislative Decree No. 1422 and Legislative Decree No. 1424, which include measures for the implementation of the General Anti-Avoidance Rule (GAAR), new thin capitalization and interest restriction rules, the definition of a permanent establishment, and other changes.

GAAR

Decree No. 1422 includes measures for the implementation of Peru's GAAR, which was first introduced in 2012, but was generally suspended pending further regulations. The Decree provides that:

• The …