The Peru tax administration (SUNAT) has published Report No. 036-2017-SUNAT/7T0000, which announces the triggering of the MFN clause included in the final protocol to the 2011 income tax treaty with Mexico. As a result, the following changes apply where the beneficial owner is a resident Mexico:
- Dividends - the maximum general rate (15%) is replaced with a 10% rate as provided in the 2012 Peru-South Korea tax treaty (original 10% rate subject to 25% ownership no longer applies);
- Interest - …