Uncertainty remains on whether tax authority will recognize tax basis of Peruvian shares acquired indirectly from January 2012 through March 2022

Legislative Decree 1529 does not include any reference to the obligation to use the Peruvian banking system for payments made to acquire Peruvian shares indirectly from 1 January 2012 and 31 March 2022.

Though recently issued Legislative Decree 1529 clarified that taxpayers do not have to use the Peruvian banking system for payments made for direct or indirect transfers of shares on or after 1 April 2022, it did not clarify whether taxpayers must use the Peruvian banking system for payments made…