Peruvian Tax Authority changes official interpretation of capital gains tax on indirect transfers under Peru-Chile DTT

08 January 2024|Tax Alerts, Information Reporting, Legislation & Policy, National/Federal Taxation, Treaties|Chile, Peru

A new ruling from the Peruvian Tax Authority interprets a provision of the Peru-Chile Double Tax Treaty pertaining to capital gains tax treatment of certain direct and indirect transfers.
The new interpretation repeals a 2021 ruling.

The Peruvian Tax Authority issued a ruling at the end of 2023 establishing that, in applying Article 21 of the Peru-Chile Double Tax Treaty (DTT), capital gains obtained by a Chilean resident from an indirect transfer of Peruvian shares through a direct transfer…

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