The Peruvian tax cost of an investment is largely decided before the money arrives: how you enter, how you fund the company, what the parent charges and how profits come back. We help you model those choices with real business substance behind them.
Tax planning is useful when it is part of a genuine commercial decision. We focus on the moments where a foreign group still has options.
Subsidiary or branch, who the shareholders will be and how that affects liability, taxation of profits and payments to headquarters.
Capital, capital contributions in kind or intercompany loans: withholding on interest, deductibility and the documentation each option needs.
Management fees, shared services, technical assistance and royalties: withholding, IGV on services used in Peru and the benefit test for deductibility.
Arm's-length pricing of related-party transactions and the documentation (local file or master file) required above certain thresholds.
Dividends, capital reductions and other routes to return cash to the group, with their timing and withholding.
Changes in shareholders, mergers or reorganizations of the Peruvian entity, coordinated with corporate services.
This is a simplified view for planning conversations, not a calculation for a specific case. Actual results depend on deductible costs, treaty position and timing.
| Flow | Peruvian tax effect | Planning question |
|---|---|---|
| Profit earned by the subsidiary | Corporate income tax at 29.5% | Which costs, including intercompany charges, are deductible? |
| Dividend paid to the foreign parent | 5% withholding on the amount distributed | When and how much to distribute, and whether a treaty may help |
| Service or management fee paid to the parent | Withholding, commonly 30% (technical assistance can be 15%); IGV on services used in Peru | Is the service real, documented and priced at arm's length? |
| Interest on a loan from the parent | Withholding on interest; deductibility limits may apply | Is debt or capital the better way to fund the company? |
SUNAT looks at what actually happened, not only at the contracts. Intercompany charges need evidence that the service was received and benefited the Peruvian entity; prices need arm's-length support; treaty relief needs a residence certificate. We do not recommend arrangements based solely on an expected tax reduction.
Most groups already have tax advisers at headquarters. We provide the Peruvian side of the analysis in English and work with them so the overall structure is consistent.
Overview: doing business in Peru →Commercial goal, entities and countries involved, amounts and intended timing.
Peruvian tax effect of each realistic option, including withholding, IGV and documentation burden.
Agreements, resolutions, transfer pricing support and evidence the Peruvian entity must keep.
Coordinate the steps with accounting and corporate teams and review the result after the first cycle.
Planning projects are quoted per matter, based on the number of alternatives, entities and jurisdictions involved. Groups that need recurring planning support alongside monthly compliance often choose a strategic scope, from USD 1,000 per month + 18% VAT (IGV) (see fees). Transfer pricing studies and advice on foreign law are quoted separately or coordinated with specialists.
Entry structure is the first planning decision. We review it as part of incorporating your company in Peru, before any document is signed.
Company incorporation for foreign investors →Before the entity is created and before significant intercompany contracts are signed. Choosing between a subsidiary and a branch, deciding how to fund the company and defining the services the parent will charge are much easier to plan than to correct later.
There is no single answer. Capital is simpler and does not generate interest; a loan can allow cash to return to the parent as interest and principal, but interest paid abroad is subject to withholding and deductibility limits may apply. We compare both for your figures before the funds are sent.
The usual route is a dividend, which carries a 5% withholding when paid to a non-domiciled shareholder, on top of the 29.5% corporate income tax paid by the subsidiary. Payments for services or royalties are an alternative only when they reflect real services priced at arm's length, and they have their own withholding.
It may reduce withholding on certain payments when the recipient is resident in a treaty country and provides a tax residence certificate. Peru's treaties include the Andean Community, Brazil, Canada, Chile, Japan, Mexico, Portugal, South Korea and Switzerland.
Our advice covers Peru. When the home-country effect matters, we coordinate with your advisers there so the Peruvian and foreign analysis fit together.
Speak with us before implementation so tax, accounting and documentation can be assessed together.