1.1.1. Income deemed to be from Peruvian sources.
Peruvian source income is considered to be income from Peruvian sources, regardless of the place of fulfillment or execution or of the contracts, domicile or nationality of the parties involved in the transactions
Those produced by properties and the rights relating to them, including those deriving from their alienation, when the properties are located in the territory of the Republic.
Those produced by goods or rights, including those coming from their alienation, when the goods are physically located, or the rights are economically used in the country.
Those produced by capital, as well as interest, commissions, premiums and any additional amount to the interest agreed for loans, credits or any other financial operation, when the capital is placed or is economically used in the country or when the payer is a subject domiciled in the country.
Dividends and any other form of distribution of profits, when the company, corporation or partner of a joint venture contract that distributes, pays or credits them, is domiciled in the country or when the investment fund, trust funds or the bank trustee that distributes, pays or credits them, are constituted or established in the country.
Those originated in civil, commercial, business or any other type of activities carried out in Mexican territory.
Those originated in personal work carried out in the national territory.
Annuities and pensions originating from personal work when they are paid by an individual or entity domiciled or incorporated in the country.
Those obtained from the sale, redemption or redemption of shares and participations representing capital, investment shares, certificates, securities, bonds and commercial papers, securities representing mortgage bonds, bearer bonds or other bearer securities and other transferable securities when the companies, corporations, Investment Funds, Mutual Funds for Investment in Securities or Trust Funds that have issued them are incorporated or established in Peru.
In the case of royalties, the income is of Peruvian source when the goods or rights for which the royalties are paid are economically used in the country or when the royalties are paid by a subject domiciled in the country.
Likewise, income from ADR’s (American Depositary Receipts) and GDR’s (Global Depositary Receipts) that have as underlying, shares issued by companies domiciled in the country are considered income from Peruvian source.
Not included in subparagraphs e) and f) is the income obtained in their country of origin by non-domiciled individuals who enter the country temporarily, in order to carry out activities related to: acts prior to making foreign investments or businesses of any kind; acts intended to supervise or control the investment or business, such as collecting data or information or conducting interviews with persons in the public or private sector; acts related to hiring local personnel; acts related to the signing of treaties or similar acts.
Likewise, income obtained from the sale of ADR's (American Depositary Receipts) and GDR's (Global Depositary Receipts) that have as underlying shares issued by companies domiciled in the country are considered as income from Peruvian source.
Those obtained from digital services rendered through the Internet or any adaptation or application of the protocols, platforms or technology used by the Internet or any other network through which equivalent services are rendered, when the service is economically used, used or consumed in the country.
Legal basis: Article 9 of the Income Tax Law.
1.1.2. Other income also considered as Peruvian source income.
They are also considered Peruvian source income:
a) Interest on bonds, when the issuing entity has been incorporated in the country, regardless of the place where the issue is made, or the location of the assets pledged as collateral.
b) Per diems, salaries, and any type of remuneration that companies domiciled in the country pay or pay to their directors or members of their boards or administrative bodies acting abroad.
c) Fees or remunerations granted by the National Public Sector to persons performing representation functions or official positions abroad.
d) The results from the contracting of Derivative Financial Instruments obtained by subjects domiciled in the country.
In the case of Derivative Financial Instruments entered into for hedging purposes, the results obtained by domiciled entities will be considered income from Peruvian source when the assets, goods, obligations, or liabilities incurred that will receive the hedge are intended to generate income from Peruvian source.
The results obtained by non-domiciled subjects from the contracting of Derivative Financial Instruments with domiciled subjects, whose underlying asset is referred to the exchange rate of the national currency with respect to another foreign currency and provided that its effective term is less than that established in the regulation, which shall not exceed one hundred and eighty days, shall also be considered as income from Peruvian source.
e) Those obtained from the indirect disposal of shares or participations representing the capital of legal entities domiciled in the country. For these purposes, it should be considered that an indirect alienation occurs when shares or participations representing the capital of a legal person not domiciled in the country that, in turn, is the owner -directly or through another legal person or persons- of shares or participations representing the capital of one or more legal persons domiciled in the country are alienated.
f) Dividends and any other form of distribution of profits distributed by a company not domiciled in the country, generated by the reduction of capital referred to in subparagraph d) of Article 24-A of the Law, provided that in the twelve (12) months prior to the distribution, the non-domiciled company had increased its capital as a result of new contributions, capitalization of credits or reorganization.
g) Those obtained from credit transfers made through factoring operations or other operations regulated by the Civil Code, in which the factor or acquirer of the credit assumes the credit risk of the debtor, when the client or transferor of the credit is a subject domiciled in the country, otherwise, when the assigned debtor is domiciled in the country.
The exporter’s income from the export of goods produced, manufactured or purchased in the country is also considered to be entirely of Peruvian source.
Legal basis: Articles 10 and 11 of the Income Tax Law.
1.1.3. Presumption of net Peruvian source income for non-domiciliaries
It is presumed, without admitting proof to the contrary, that taxpayers not domiciled in the country and branches, agencies or any other permanent establishment in the country of sole proprietorships, partnerships and entities of any nature incorporated abroad, that carry out the activities referred to below, obtain net income from Peruvian sources equal to the amounts resulting from the application of the percentages established below for each of them:
Presumptions of net income for non-domiciled persons
Subparagraph | Activity | Percentage |
|---|---|---|
a) | Insurance activities | 7% of premiums |
b) | Warehouse rental | 80% of the gross income received from such activity. |
c) | Aircraft rental | 60% of the gross income received for such activity |
d) | Transportation between the Republic of Peru and abroad | 1% of the gross income from air transportation and 2% of the gross income from chartering or maritime transportation, except in those cases in which, due to reciprocity with the treatment granted to Peruvian lines operating in other countries, the exemption from Income Tax for foreign lines with headquarters in such countries is applicable. The non-domiciled company shall prove the exemption by means of a certificate issued by the Tax Administration of the country where it has its headquarters, duly authenticated by the Peruvian Consul in such country and legalized by the Ministry of Foreign Affairs. |
e) | Telecommunication Services between the Republic of Peru and foreign countries. | 5% of gross income. |
f) | International news agencies | 10% on the gross remuneration obtained for the supply of news and, in general, informative or graphic material, to persons or entities domiciled or using such material in the country. |
g) | Distribution of cinematographic and similar films for use by domiciled individuals or legal entities. | 20% on the gross income received from the use of cinematographic or television films, video tapes, radio soap operas, phonograph records, graphic cartoons and any other similar means of projection, reproduction, transmission or dissemination of images or sounds. |
h) | Companies that supply containers for transportation in the country or from the country to foreign countries and do not provide transportation services. | 15% of the gross income obtained from such supply. |
i) | Container demurrage for transport. | 80% of the gross income obtained from the overstay of containers. |
j) | Assignment of television broadcasting rights | 20% of the gross income obtained by non-domiciled taxpayers from the assignment of rights for the retransmission on television in the country of live events held abroad. |
Legal basis: Article 48 of the Income Tax Law.
1.1.4. Classification by category of Peruvian source income
Peruvian source income is classified in the following categories:
1.1.4.1. First Category Income
Income obtained from leasing, subleasing and assignment of assets, as detailed below, constitute first category income:
a) The proceeds in cash or in kind from the lease or sublease of premises, including their accessories, as well as the amount agreed for the services provided by the lessor and the amount of the taxes paid by the lessee and which legally correspond to the lessor.
b) Those produced by the lease or temporary assignment of movable or immovable property, not included in the preceding subparagraph, as well as the rights thereon, including those included in the preceding subparagraph.
c) The value of the improvements made to the property by the lessee or sublessee, insofar as they constitute a benefit for the owner and in the part that the latter is not obliged to reimburse.
d) The fictitious rent of properties whose occupation has been assigned by their owners free of charge or at an undetermined price.
Legal basis: Subparagraph a) of article 9 and article 23 of the Income Tax Law.
1.1.4.2. Second Category Income
Second Category income is income obtained as a result of:
a) Interest originated in the placement of capital, as well as capital increases or readjustments, whatever their denomination or form of payment, such as those produced by securities, bonds, debentures, bonds, guarantees and privileged or unsecured credits in money or securities.
b) Interest, surpluses and any other income received by members of cooperatives as remuneration for their contributed capital, with the exception of those received by members of worker cooperatives.
c) Royalties.
d) Proceeds from the definitive or temporary assignment of key rights, trademarks, patents, royalties or similar.
e) Annuities.
f) The sums or rights received in payment of obligations not to do, unless such obligations consist of not carrying out activities included in the third, fourth or fifth category, in which case the respective income shall be included in the corresponding category.
g) The difference between the updated value of the premiums or quotas paid by the insured and the sums that the insurers deliver to them upon the expiration of the term stipulated in the life insurance endowment contracts and the benefits or participations in life insurance obtained by the insured.
h) The attribution of profits, income or capital gains from investment funds, trust assets of securitization companies, including those resulting from the redemption or redemption of securities issued on behalf of such funds or assets, and bank trusts.
i) Dividends and any other form of distribution of profits.
j) Capital gains.
k) Any gain or income derived from operations carried out with derivative financial instruments.
l) Income produced by the alienation, redemption or redemption, as the case may be, which is carried out on a regular basis, of shares and participations representing capital, investment shares, certificates, securities, bonds and commercial papers, securities representing mortgage bonds, certificates of participation in mutual funds for investment in securities, bearer or other bearer obligations and other marketable securities.
Legal basis: Articles 24, 26 and 27 of the Income Tax Law.
1.1.4.3. Third Category Income
Third Category Income includes income derived from commerce, industry and others, as detailed below:
(a) Those derived from trade, industry or mining; from the exploitation of agriculture, livestock, forestry, fishing or other natural resources; from the rendering of commercial, industrial or similar services, such as transportation, communications, sanatoriums, hotels, warehouses, garages, repairs, construction, banking, financial, insurance, bonds and capitalization; and, in general, from any other activity that constitutes habitual business of purchase or production and sale, exchange or disposition of goods.
b) Those derived from the activity of commercial brokers, auctioneers and auctioneers and any other similar activity.
c) Those obtained by the Notaries.
d) Capital gains and income from regular operations.
e) Other income obtained by legal entities and companies domiciled in the country, regardless of the category to which it should be attributed.
f) Income obtained from the exercise in association or in civil society of any profession, art, science or trade.
g) Any other income not included in the other categories
h) The derived from the transfer of real or personal property other than land, whose depreciation or amortization is allowed by this law, made by taxpayers generating third category income, free of charge, at an undetermined price or at a price lower than the market price; to other taxpayers generating third category income or to entities included in the last paragraph of article 14 of this law.
i) Income obtained by Private Educational Institutions.
j) Income generated by Trust Patrimonies of Securitization Companies, Banking Trusts and Business Investment Funds, when they come from the development or execution of a business or company.
Legal basis: Article 28 of the Income Tax Law.
1.1.4.4. Fourth Category Income
Fourth Category Income is defined as income from self-employment, as detailed below:
a) The individual exercise of any profession, art, science, trade or activity not expressly included in the third category.
b) The performance of the functions of company director, trustee, representative, business manager, executor and similar activities, including the performance of the functions of municipal councilor or regional councilor, for which they receive per diems.
Legal basis: Article 33 of the Income Tax Law.
1.1.4.5. Fifth Category Income
Fifth Category Income includes income from employment as an employee, and other income from self-employment, as detailed below:
a) Personal work rendered in a relationship of dependency, including public offices, elective or not, such as salaries, wages, allowances, emoluments, bonuses, per diems, gratuities, bonuses, Christmas bonuses, commissions, compensation in cash or in kind, representation expenses and, in general, any remuneration for personal services.
The amounts received by the public servant for service matters in a place other than his usual residence, such as travel expenses, per diems for food and lodging expenses, mobility expenses and other expenses required by the nature of his work, shall not be considered as such, provided that they do not constitute sums that by their amount reveal the purpose of evading the tax.
In the case of public officials who, by reason of their service or special commission, are abroad and receive their salary in foreign currency, only the income that they would be entitled to receive in the country in national currency, according to their grade or category, shall be considered as taxable income in this category.
b) Annuities and pensions that originate from personal work, such as retirement, disability and disability pensions, and any other income that originates from personal work.
c) Employees’ participations, whether from annual allowances or any other benefit granted in lieu thereof.
d) Income received by members from worker cooperatives.
e) Income obtained from work rendered independently, with service rendering contracts regulated by civil legislation, when the service is rendered at the place and time designated by whoever requires it and when the user provides the work elements and assumes the expenses that the rendering of the service demands.
f) Income obtained from the rendering of services considered within the fourth category, carried out for a contractor with whom an employment relationship of dependence is maintained at the same time.
Legal basis: Article 34 of the Income Tax Law.
1.1.5. Taxable base for non-domiciled persons
Persons or entities paying or crediting non-domiciled beneficiaries with Peruvian source income of any nature, must withhold and pay to the tax authorities, within the terms established by the Tax Code for monthly obligations, the taxes referred to in articles 54 and 56 of this law, as the case may be.
For the purposes of such withholding, they are considered net income, without admitting proof to the contrary:
a) The totality of the amounts paid or credited corresponding to income of the first category.
b) The totality of the amounts paid or credited corresponding to income of the second category, except for the cases referred to in subparagraph g) of this article.
c) The amounts resulting from applying to the amounts paid or credited for the concepts referred to in Article 48 of the Income Tax Law, the percentages established in said provision.
d) The totality of the amounts paid or credited corresponding to other income of the third category, except in the cases referred to in subparagraph g) of this article.
e) Eighty percent (80%) of the amounts paid or credited for fourth category income.
f) The totality of the amounts paid or credited corresponding to income of the fifth category.
g) The amount resulting from deducting the recovery of the invested capital, in the cases of income not included in the previous subparagraphs, arising from the disposal of assets or rights or from the exploitation of assets subject to wear and tear. The deduction of the invested capital shall be made in accordance with the rules to be established for such purpose in the regulations.
Legal basis: Article 76 of the Income Tax Law.
1.1.6. Tax rates applicable to non-domiciled
Individuals not domiciled in the country.
Individuals and undivided estates not domiciled in the country will be subject to tax on their Peruvian source income at the following rates:
Subparagraph | Type of income | Rate |
|---|---|---|
a) | Dividends and other forms of profit distribution, except for those indicated in subparagraph f) of Article 10 of the Law. | 5%
|
b) | Capital gains from the sale of real estate | 5% |
c) | Interest, when paid or credited by a third category income earner domiciled in the country. This rate is applicable, provided that there is no relationship between the parties or when the interest does not derive from operations carried out from or through non-cooperating countries or territories or low or no taxation; or with subjects that obtain income, income or profits subject to a preferential tax regime for such operations, in which case the rate of 30% is applied. | 4,99%
|
d) | Capital gains from the sale of marketable securities outside the country. | 30% |
e) | Other income from capital. | 5% |
f) | Income from activities included in article 28 of the law. | 30% |
g) | Income from work. | 30% |
h) | Royalty income. | 30% |
i) | Income from performers for live shows performed in the country. | 15% |
j) | Other income different from those indicated in the previous subparagraphs. | 30% |
Legal basis: Article 54 of the Income Tax Law.
Legal entities not domiciled in the country
Subparagraph | Type of income | Tasa |
j) | Other income, including interest derived from foreign credits that do not comply with the requirement established in subclause 1) of paragraph a) or in the part that exceeds the maximum rate established in subclause 2) of the same paragraph; interest paid abroad by private companies of the country for credits granted by a foreign company with which it is related; or, interest paid abroad by private companies of the country, for credits granted by a creditor whose intervention has the purpose of concealing a credit operation between related parties. The provisions of the first paragraph shall not be applicable to the companies referred to in subparagraph b). It is understood that there is a credit operation in which the creditor's intervention has had the purpose of concealing a transaction between related companies, when the debtor domiciled in the country cannot demonstrate that the structure or legal relationship adopted with its creditor coincides with the economic event that the parties intend to carry out. | 30% |
Legal basis: Subparagraph j) of article 56 of the Income Tax Law.
1.1.7. Withholding tax for non-domiciled persons
The persons or entities that pay or credit to non-domiciled beneficiaries, income of Peruvian source of any nature, must withhold and pay to the Treasury definitively, within the terms provided by the Tax Code for monthly obligations, the taxes referred to in articles 54 and 56 of the Income Tax Law, as the case may be. If the person paying or crediting Peruvian source income to non-domiciled beneficiaries is a Securities Clearing and Settlement Institution or whoever performs similar functions incorporated in the country, the following shall be taken into account:
a) The withholding for interest shall be made in all cases at the rate of four point ninety-nine percent (4.99%), and the non-domiciled taxpayer shall be responsible for the payment of the higher Tax resulting from the application referred to in subparagraph c) of Article 54 and j) of Article 56 of the Law.
b) In the case of second category income originated by the alienation, redemption or redemption of the assets referred to in subparagraph a) of Article 2 of this Law, the withholding shall be made at the time the cash compensation and liquidation is made. For the purpose of determining the computable cost, the non-domiciled subject must register before the referred institution the respective computable cost, as well as the expenses incurred that are related to the acquisition of the disposed securities, which must be supported with the documents issued by the respective entities or participants that have intervened in the acquisition or disposal operation of the securities.
In the case of indirect disposals of shares or participations representing the capital of legal entities domiciled in the country, the withholding shall be made at the time of cash clearing and settlement, provided that the non-domiciled entity notifies the securities clearing and settlement institutions or whoever performs similar functions of the indirect disposal of shares or participations, as well as the amount to be withheld, attaching the supporting documentation.
The communication referred to in the preceding paragraph may be made through authorized third parties.
Legal basis: Article 76 of the Income Tax Law.
1.1.8. Filing and payment of tax withheld
Obligations for the sale of real estate located in the country
As a non-domiciled taxpayer, if a taxpayer sells a property, the buyer who is a domiciled taxpayer is obliged to withhold Income Tax, paying it through the PDT Other Withholdings - Virtual Form No. 617.
The withholding in this case is calculated by applying the rate of five percent (5%) for being income from the transfer of real estate, in accordance with the provisions of subparagraph b) of article 54° of the TUO of the Income Tax Law (rate in force as of 01.01.2017).
In the event that only the PDT is submitted without the cancellation of the corresponding withholding, the payment of the tax must be made through the Easy Payment System, Form No. 1662 - Payment Slip, entering as tax code 3062 (Non-domiciled Withholdings).
Obligations for the rental of real estate located in the country
If a non-domiciled person rents a property located in the country, the domiciled lessee is obliged to withhold income tax, which will be determined and paid using the PDT Other Withholdings - Virtual Form No. 617.
The withholding to be made shall be calculated by applying the rate of five percent (5%) of the income from the rental of real estate, in accordance with the provisions of subparagraph b) of article 54 of the TUO of the Income Tax Law.
In case the tax is not paid together with said PDT, the payment shall be made by means of Form No. 1662 - Payment Slip, indicating as tax code 3062 (Non-domiciled Withholdings).
Obligations arising from the sale or transfer of marketable securities
If a taxpayer sells securities as a non-domiciled person, generating income of Peruvian source, which is settled by a Securities Clearing and Settlement Institution, a withholding on account of the tax must be made at the time the cash settlement is made, applying the rate of five percent (5%).
In order to determine the amount of the withholding, the aforementioned liquidation entity shall subtract the acquisition cost (computable cost) from the income obtained as a consequence of the sale of the securities.
In order to determine the computable cost, this must be registered before the Securities Clearing and Settlement Institution, as well as the expenses incurred related to the acquisition of the securities sold.
Obligations for fourth category income
If, as a non-domiciled person, the service user receives fourth category income for the rendering of services independently, the service user who is a domiciled person will apply the 30% withholding on the net income (i.e., deducting 20% of the non-domiciled person’s income) and the user of the services will make the declaration and payment through the Electronic Payroll PDT (PDT of Electronic Payroll - PLAME).
Obligations for fifth category income
If the taxpayer is not domiciled and is on the payroll, his employer will withhold 30% of the total income obtained from paid work, declaring and paying the aforementioned amount through the PDT of Electronic Payroll - PLAME at the expense of the user of the services.
1.1.9. Jointly Liable Parties for Withholding and Payment
Persons or entities that pay Peruvian source income of any nature to non-domiciled persons or entities must withhold and pay to the tax authorities, within the periods established by the Tax Code for monthly obligations, the Income Tax.
Royalties and retributions for services, technical assistance, assignment in use or others of similar nature in favor of non-domiciled beneficiaries may be deducted as a cost or expense in the taxable year to which they correspond when they have been paid or credited within the term established by the regulations for the submission of the affidavit corresponding to such year.
1.1.10. Instruments to avoid double taxation
Double or multiple taxation occurs when two or more countries consider that they have the right to tax a certain income. In such cases, the same income may be taxed by more than one State.
In order to face and resolve cases of international double taxation, States enter into agreements or conventions to regulate this situation. These agreements contemplate not only the rules to be used to avoid double taxation but also the mechanisms for collaboration between Tax Administrations in order to detect cases of tax evasion.
Through the use of treaties, the signatory States waive the taxation of certain profits and agree that only one of the States has the power to tax or, in any case, that there is shared taxation, i.e., that both States collect part of the total tax payable by the taxpayer.
The Double Taxation Avoidance Agreements (DTA) that Peru has in force are the following: https://www.mef.gob.pe/es/convenio-para-evitar-la-doble-imposicion
For more information on international conventions and agreements, please contact:
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MUTUAL AGREEMENT PROCEDURE (MAP)
The PAM is an alternative dispute resolution procedure incorporated in the IDCs signed by Peru to prevent and resolve disputes related to the interpretation or application of the provisions of the IDCs in a timely manner.
In accordance with the minimum standard of Action 14 of the BEPS Plan and the international commitments assumed by the country, a guide is published that establishes the rules, guidelines and procedures on the access and use of the PAM, in order to provide clarity, certainty and transparency for those who opt for this alternative dispute resolution mechanism within the framework of the provisions of the IDCs.
MAP’s Guide –English version
For more information on the Mutual Agreement Procedure (MAP), please contact:
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1.1.11. Frequently Asked Questions
i. Peruvian source income
Do I have to pay taxes if I do not reside in Peru, but I have Peruvian source income?
If you are a non-domiciled person, you must make specific withholdings from your income obtained in Peru in favor of SUNAT according to the following cases:
Sale of real estate in Peru: the buyer with domiciliary status is obliged to withhold 5% of the payment.
Rental of real estate located in Peru: the domiciled tenant is obliged to withhold 5% of the rental amount.
Sale or transfer of securities: if you generate Peruvian source income for this action, which was settled by a Securities Clearing or Settlement institution, you must withhold 5%.
4th category income: if you provide services independently, the user with domiciled status must withhold 30% of your net income.
5th category income: if you are on the payroll, your employer must withhold 30% of your pay.
Source: https://www.gob.pe/8004-tributacion-de-personas-no-domiciliadas
ii. Foreign source income
Do I have to pay taxes if I reside in Peru, but I have income from abroad?
If you live in Peru but have income from abroad (Foreign Source Income), you must add it to your Peruvian source income and pay a tax on it.
- They are foreign source income, for example:
- Income obtained from renting a property located abroad.
- Interest earned on bank deposits in foreign financial institutions.
- Income obtained for rendering services abroad.
- Profits received from a company domiciled in another country.
- Income obtained from the sale of shares issued by a company of another country, traded on the stock exchange of another country (*)
- Income obtained from the sale of shares issued by a company of another country, traded on the Lima Stock Exchange (*).
(*) It is considered Foreign Source Income because the entities that issue these securities are not domiciled in Peru.
As a general rule, foreign source income is added to earned income and the tax is paid at the time of submitting the annual affidavit.
Such income is added and compensated among themselves and only if such operations result in a net income, it will be added to the Peruvian source income.
These foreign source incomes are not categorized and are considered for income tax purposes as long as they have been received.
Source: https://personas.sunat.gob.pe/tengo-ingresos-extranjero
1.1.12. Reports issued by SUNAT
REPORT No. 278-2001-SUNAT/K00000
https://www.sunat.gob.pe/legislacion/oficios/2001/oficios/i2782001.htm
REPORT No. 011-2005-SUNAT/2B0000
https://www.sunat.gob.pe/legislacion/oficios/2005/oficios/i0112005.htm
REPORT No. 229-2005-SUNAT/2B0000
https://www.sunat.gob.pe/legislacion/oficios/2005/oficios/i2292005.htm
REPORT No. 039-2009-SUNAT/2B0000
https://www.sunat.gob.pe/legislacion/oficios/2009/oficios/i039-2009.htm
REPORT No. 8-2012-SUNAT/2B0000
https://www.sunat.gob.pe/legislacion/oficios/2012/informe-oficios/i008-2012a.pdf
REPORT No. 054-2014-SUNAT/4B0000
https://www.sunat.gob.pe/legislacion/oficios/2014/informe-oficios/i054-2014.pdf
REPORT No. 087-2014-SUNAT/5D0000
https://www.sunat.gob.pe/legislacion/oficios/2014/informe-oficios/i087-2014-5D0000.pdf
REPORT No. 095-2018-SUNAT/7T0000
https://www.sunat.gob.pe/legislacion/oficios/2018/informe-oficios/i095-2018-7T0000.pdf
1.1.13 Jurisprudence of the Tax Court and the Court of Justice of the Andean Community
RTF N.° 7645-4-2005 Reimbursement of lodging and travel expenses for a non-domiciled individual to render a service in the country constitutes Peruvian source income.
https://www.mef.gob.pe/contenidos/tribu_fisc/Tribunal_Fiscal/PDFS/2005/4/2005_4_07645.pdf
RTF N.° 162-1-2008 y N.° 18368-8-2012 – Technical assistance services whose remuneration constitutes income from Peruvian sources.
https://www.mef.gob.pe/contenidos/tribu_fisc/Tribunal_Fiscal/PDFS/2008/1/2008_1_00162.pdf
https://www.mef.gob.pe/contenidos/tribu_fisc/Tribunal_Fiscal/PDFS/2012/8/2012_8_18368.pdf
CAN Process 85-IP-2017 - Income tax and Call Center serviceshttps://www.comunidadandina.org/DocOficialesFiles/Procesos/85_IP_2017.pdf