Peru issues resolution on international merger operation between two non-domiciled companies

13 October, 2020

On 6 October 2020, the Peruvian tax authorities (SUNAT) issued Resolution No. 061-2020-SUNAT / 7T0000 Official Website, through which the following has been concluded:

The permanent establishment must maintain the same RUC number and notify SUNAT of the corresponding changes in order to update its information in the said registry; as long as it continues with its activities and the merger involves only the change of its original parent company.
For the purposes of the Income-tax Law, on the occasion of the merger:
- Regarding such assets there is no disposal by the permanent establishment;
- The income that becomes evident as a result of the disposal of the permanent establishment qualifies as taxed income from Peruvian sources generated by the absorbed company.

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