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Peruvian Tax Court holds international migration into Double Tax Treaty country does not prevent per se application of Double Tax Treaty benefits

|Tax Alerts, National/Federal Taxation, Treaties|Canada, Peru
Canada, Peru
  • The Peruvian Tax Court recently published Resolution 08835-12-2012, establishing that the migration of an entity from Panama to Canada which in turn owns the shares of a Peruvian company, does not prevent the application of the benefits of the Peru-Canada Double Tax Treaty (DTT) for capital gains, upon the subsequent sale of the Peruvian shares.

Background

The Peruvian Tax Court analyzed the case of a legal entity which was a shareholder of a Peruvian entity that migrated from Panama to Canada in …

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