Peru

Corporate - Corporate residence

Last reviewed - 10 February 2025

For income tax purposes, the following entities, among others, are considered as resident entities in Peru:

  • Corporations duly incorporated in Peru.
  • Branches, agencies, and PEs in Peru of non-resident individuals or entities.
  • Partnerships and limited liability companies.

Permanent establishment (PE)

The following scenarios might trigger a PE presence in Peru:

  • Any fixed place of business in which the activities of a foreign Company are totally or partially carried out.
  • A building site or construction or installation project, as well as supervision activities related to them, when their duration exceeds 183 days within any 12 month period, unless a lower term has been established through a Double Tax Treaty. 
  • The provision of services, when they are performed in the country for the same project, service or for a related one, for a period
    or periods that in total exceed 183 days within any 12 month period, unless a lower term has been established through a Double
    Tax Treaty.
  • A person acting in the country on behalf of a foreign Company and, in doing so, habitually concludes contracts, or habitually plays the principal role leading to the conclusion of contracts that are that are routinely concluded without material modification by the foreign Company.

    PEs must comply with all the formal and substantial tax obligations of any domiciled taxpayer. If a PE presence is determined, then the tax contingency will have to be quantified by calculating the taxes, fines, and interest accrued as from the moment in which the PE presence can be deemed, except for the period barred by statute of limitations.