Peruvian Tax Authority interprets Non-Discrimination Clause of Multinational Agreement to avoid Double Taxation as not applicable to transfer of Peruvian shares in international reorganizations

01 August 2023|Tax Alerts, Information Reporting, Legislation & Policy, National/Federal Taxation, Treaties|Peru

The Peruvian Tax Authority analyzed whether, in a demerger situation between two Colombian entities in which the assets transferred include Peruvian shares, the Non-Discrimination Clause of Decision 578 would apply to invoke the tax-free regime for Peruvian domestic reorganizations.
The Tax Authority interpreted that, because the domestic rules for demergers require not only that the spun-off entity be a Peruvian resident but also that the receiving entity be a Peruvian resident, the Non-Discrimi…

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