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.