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Peru Clarifies Interest Reduction Restriction Not Applicable for Loans Used to Finance Foreign-Source Income

|Approved Changes|Peru
Peru

On 23 April 2019, the Peru tax authority (SUNAT) published Report No. 033-2019-SUNAT/7T0000 concerning the application of Peru's thin capitalization rules, which include a restriction on the deduction of interest on loans where a debt-equity ratio of 3:1 is exceeded. The report addresses the question of whether interest on a loan received from a related party by an entity resident in Peru will be subject to the thin cap rules if the funds are used for the realization of investments that will…

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