IHG Perú Sociedad Comercial de Responsabilidad Limitada (IHG) [Counterparty: Peruvian Tax Authority (SUNAT)]

Request for information over tax domicile. We are assisting the IHG in responding a request for information issued by Peruvian Tax Authority (SUNAT), regarding the client’s declared tax domicile. Analysis of potential tax haven: We also advised IGH on tax matters over business schemes in Peru. Particularly, we analysed the qualification of Delaware as a potential tax haven according to Peruvian regulations. In this regard, we worked with a Delaware law firm to carry out our analysis. As a result, Delaware was ruled out as a tax haven and was able to continue with the business scheme. Trusted tax advisor: IHG is a client to whom we provide ongoing tax advice. It is a client that constantly turns to us to resolve tax concerns and queries related to SUNAT requirements, determination of its Income Tax and IGV, operations with non-domiciled persons, issuance of Electronic Remittance Guides, etc. Latest development: We continue assisting the client with this matter.

Matter value – include currency and amount in figures :

Confidential

Is this a cross-border matter? If yes, please indicate the jurisdictions involved :

Yes: Peru; USA

Lead partner :

Michael Morales

Other team members :

Nataly Aspinwall

Other firms advising on the matter and their role(s) :

Richards, Layton & Finger, P.A. (USA Counsel to the client)

Date of completion or current status :

Ongoing