Doing Business In... 2025

PERU Law and Practice Contributed by: Alvaro Echeandía, Alfred Kossuth Wieland, Pilar Santillán Meza and Rodrigo Varillas Cueto, Thorne, Echeandia & Lema Abogados

Amazonian Regime The main tax benefits for the Amazonian area include, subject to certain requirements, the exemption from income tax, or a reduced income tax rate of 5% or 10% for certain areas. Benefits also include a general exemption from VAT for import and sale of goods or services within the Amazonian area, the application of an additional tax credit, and exemptions from excise tax and VAT on the sale of fuel in specific Amazonian areas. Mining Mining activities are subject to rules and regu - lations providing several tax benefits and war - ranties to promote them. Hence, specific rules apply for amortising the purchase of mining con - cessions, and for deducting mine exploration, development and implementation expenses. The system also offers tax stability and the deduc - tion of investments in infrastructure related to utilities and public services, provided certain requirements are fulfilled. Special Economic Zones (SEZ) Certain geographic areas are subject to particu - lar tax benefits aimed at promoting their eco - nomic development. These tax benefits include exemption from income tax, VAT, excise tax, ad valorem tariff and from other tax obligations. Currently, the most important free zones are located in Tacna, Ilo and Paita. Aquaculture Aquaculture companies with annual revenues up to 1,700 UIT qualify for a reduced corporate income tax rate of 15% until 2032. In 2025, the same tax rate applies for companies with annual revenues of more than 1,700 UIT, with a tax rate of 20% until 2029, and a tax rate of 25% from 2030 to 2032. After that time, aquaculture com - panies will be subject to the general income tax

rate. Investments in canals and harvesting infra - structure can be depreciated at a rate of 20%. Forestry and Wildlife Companies involved in forestry and wildlife activities with annual revenues up to 1,700 UIT qualify for a 15% corporate income tax rate until 2030, being subject to the general tax rate there - after. In cas annual revenues exceed 1,700 UIT, between 2025 and 2027 the applicable tax rate will be 25%, after which time the general income tax rate will apply. Investments in infrastructure for forest and wild - life management can be depreciated at a rate of 20%. Small and Medium-Sized Businesses A small and medium-sized companies system applies to taxpayers with annual revenues up to 1,700 UIT. Under this system, the taxpayer’s net income equivalent to 15 UIT is taxed at a 10% corporate income tax rate, and the excess is subject to the regular 29.5% tax rate. For pur - poses of the monthly advanced payments, if the company’s annual net revenue is less than 300 UIT, the monthly payment is equivalent to 1% of the net income. Otherwise, the monthly pay - ment is determined under the general income tax rules. 5.4 Tax Consolidation As of 2025, there is no tax consolidation regime in force in Peru. 5.5 Thin Capitalisation Rules and Other Limitations The current CIT considers interest from debt as a deductible expense for the determination of net income, when the loan amount is used to obtain taxable income or maintain the source of income.

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