Peru Tax Authority Holds Chilean Investment Funds Not Qualified as Residents Under Tax Treaty with Chile

The Peru tax authority (SUNAT) recently published Report No. 143-2020-SUNAT/7T0000 concerning two questions: (1) Are dividends paid by a company incorporated in Peru to a shareholder company resident in Chile subject to withholding; and (2) Is the treatment different if the shareholder is a private investment fund in Chile?

With respect to the first question, it is clarified that under domestic law, dividends paid from Peru to persons not domiciled in Peru are subject to withholding tax in …