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Countries › Peru › Guide › 4. Entities and setup › Beneficial ownership declaration in Peru: who counts, Form 3800, deadlines and penalties

Beneficial ownership declaration in Peru: who counts, Form 3800, deadlines and penalties

Last verified: 2026-10-28 · Status: Changing

Every Peruvian company and every legal arrangement such as a trust, investment fund or consortium must identify the individuals who ultimately own or control it and declare them to SUNAT on Virtual Form 3800. A beneficial owner is any individual holding at least 10 percent of capital directly or indirectly, anyone who controls by other means, and failing both the most senior manager. The phased rollout ends with the November 2026 period for the remaining domestic companies, companies that obtain a RUC after 30 November 2026 file in the period they register, and notaries report non filers to SUNAT every month.

USD figures use S/ 3.452 per US dollar, the banking system selling rate published by the Superintendencia de Banca, Seguros y AFP for 27 October 2026, the latest value in the Banco Central de Reserva del Perú statistics series PD04640PD on the verification date. Fees stated as a percentage of the UIT use the 2026 UIT of S/ 5,500 (Decreto Supremo Nº 301-2025-EF, as cited by Resolución de Superintendencia Nº 000016-2026/SUNAT). Conversions are for orientation only.

Key facts

Ownership threshold for a beneficial owner10 % of capital, direct or indirectDL 1372 art. 4.1 a), as of 2026-10-28 · in force
Beneficial ownership filing formFormulario Virtual 3800 RS 185-2019/SUNAT art. 3, as of 2026-10-28 · in force
Authority receiving the declarationSUNAT DL 1372 art. 3.1 b), as of 2026-10-28 · in force
Last schedule period for remaining domestic companiesNovember 2026 RS 000168-2025/SUNAT art. 3, as of 2026-10-28 · in force
Filing deadline for companies registering for a RUC after 30 Nov 2026Due date of the period of RUC registration or activation RS 000168-2025/SUNAT art. 3 c), as of 2026-10-28 · in force
Fine for late filing of the declaration (Table I)30 % of UITCódigo Tributario art. 176 num. 2, as of 2026-10-28 · in force
Business days each month for notaries to report non filers10 business daysRS 185-2019/SUNAT art. 12, as of 2026-10-28 · in force

The rule

1. Who must file and why. Decreto Legislativo Nº 1372 requires legal persons and legal arrangements to inform the identity of their beneficial owners, so that authorities have timely, accurate and updated information to fight tax evasion and avoidance, money laundering and terrorist financing and to meet mutual tax assistance obligations. The duties to identify, obtain, update, declare, keep and provide the information continue even during dissolution, liquidation or bankruptcy, when they pass to liquidators or administrators. Legal arrangements include trusts and investment funds, trusts formed abroad with a trustee or protector domiciled in Peru, and contracts by which two or more persons associate without forming a legal person, including consortia.Decreto Legislativo Nº 1372, Art. 1, art. 2 and art. 3.1, 2018-08-02 official text · verified 2026-10-28
2. Who is a beneficial owner of a company. (a) Any individual who directly or indirectly, by any form of acquisition, holds at least 10 percent of the capital of the legal person, with the ownership chain reported where the holding is indirect; (b) any individual who, alone or with others acting as a decision unit, or through other persons or arrangements, has powers by means other than ownership to appoint or remove most of the management, direction or supervision bodies, has decision power over financial, operating or commercial agreements, or exercises other control, with the control chain reported; and (c) where no individual is identified under (a) or (b), the individual holding the most senior administrative position. For trusts and funds, settlors, trustees, beneficiaries and anyone with effective final control count. The term is read in line with FATF recommendations.Decreto Legislativo Nº 1372, Art. 4.1, art. 4.2 and art. 4.3, 2018-08-02 official text · verified 2026-10-28
3. Internal procedure and record keeping. Companies and arrangements must implement an internal procedure with reasonable mechanisms to obtain and keep adequate (sufficient, relevant and valid) and precise information on their beneficial owners: identify and validate them, keep the data updated, keep the information and supporting documents for the period set by the rules, and give authorities timely access. Beneficial owners must disclose their identity and supporting information to the company and report changes. If after applying the criteria the identity cannot be obtained, the company must publish that fact in a suitable public medium. False information triggers sector sanctions and possible criminal action.Decreto Legislativo Nº 1372, Art. 6 and art. 8.3, 2018-08-02 official text · verified 2026-10-28
4. Form 3800 and updates. The declaration is filed on Formulario Virtual Nº 3800, Declaración del Beneficiario Final, in SUNAT Virtual. Data can be keyed directly only when a single beneficial owner resident in Peru holds directly at least 10 percent of capital; in all other cases the information is attached in SUNAT's spreadsheet formats, including the ownership or control chain. Declared information must be updated within the periods set in art. 9 of the regulation (Decreto Supremo Nº 003-2019-EF) by filing a new declaration. A declaration can be substituted until its due date and rectified afterwards if it contains errors.Resolución de Superintendencia Nº 185-2019/SUNAT, Art. 3, art. 6, art. 9 and art. 10, 2019-09-23 official text · verified 2026-10-28
5. Filing schedule for remaining domestic companies. Domestic legal persons not covered by the earlier waves (principal taxpayers in 2019 and companies with net income above 300 UIT under Resolución Nº 000041-2022/SUNAT) file by the due date of the monthly schedule for the period that matches their 2024 net income: more than 100 UIT, October 2025; more than 50 to 100 UIT, December 2025; more than 25 to 50 UIT, July 2026; more than 10 to 25 UIT, September 2026; up to 10 UIT, November 2026. The November 2026 period also applies to companies not obliged to file all tax returns, companies outside the bands, companies with a RUC obtained but not activated by 31 December 2024, and companies registered or activated from 1 January 2025 to 30 November 2026; domestic legal arrangements registered from 1 October 2024 to 30 November 2026 also file for November 2026. Companies and arrangements that register for a RUC after 30 November 2026 file by the due date for the period in which they register or activate their RUC. The declaration shows beneficial owners as of the last day of that period. The UIT used for the bands is the 2024 UIT.Resolución de Superintendencia Nº 000168-2025/SUNAT, Art. 2 i) and art. 3, 2025-05-26 official text · verified 2026-10-28 · changed: Resolución Nº 000168-2025/SUNAT (26 May 2025) set the final waves, from the October 2025 period to the November 2026 period, and first period filing for RUC registrations after 30 November 2026.
6. Notaries as gatekeepers. SUNAT gives notaries online access to check whether a company has filed its beneficial ownership declaration, and notaries who learn in their work that a company has not filed must report it to SUNAT through SUNAT Operaciones en Línea within the first ten business days of each month.Decreto Legislativo Nº 1372, art. 9; Resolución de Superintendencia Nº 185-2019/SUNAT, DL 1372 art. 9; RS 185-2019 art. 11 and art. 12, 2019-09-23 official text · verified 2026-10-28
7. Penalties. For companies with business (third category) income, Table I of the Tax Code fines failure to file declarations other than tax returns within the deadline at 30 percent of the UIT (art. 176 numeral 2), and filing other declarations or communications incomplete or not matching reality at 30 percent of the UIT or 0.6 percent of net income in the cases of note 14 (art. 176 numeral 4, an item rewritten by Decreto Legislativo Nº 1372).
Cost to do it: 30 percent of the 2026 UIT = S/ 1,650 (about US$477.98) per infraction, before any reduction under SUNAT's graduality rules.
Example: A company that misses its November 2026 period deadline faces a fine of S/ 1,650. / About US$477.98.Texto Único Ordenado del Código Tributario, Decreto Supremo Nº 133-2013-EF, Art. 176 numerals 2 and 4, Table I, 2013-06-22 official text · verified 2026-10-28
2024 net income bandPeriod whose due date applies
More than 100 UITOctober 2025
More than 50 up to 100 UITDecember 2025
More than 25 up to 50 UITJuly 2026
More than 10 up to 25 UITSeptember 2026
Up to 10 UIT, and companies registered 1 Jan 2025 to 30 Nov 2026November 2026
RUC obtained or activated after 30 Nov 2026Period of registration or activation

Final filing waves under Resolución Nº 000168-2025/SUNAT (domestic companies, 2024 net income)

Worked example

  • A Peruvian S.A.C. is owned 99 percent by a Spanish holding company that is 60 percent owned by a family trust and 40 percent by an individual investor. The investor holds about 39.6 percent indirectly and is a beneficial owner; the trust's settlor, trustee and beneficiaries are reported under the trust criteria; the ownership chain is attached to Form 3800 in SUNAT's spreadsheet format, because direct keying is only allowed for a single Peruvian resident owner holding directly.

Step by step

  1. Map the ownership and control chain up to individuals and apply the 10 percent, control and senior manager tests in that order.
  2. Collect identity data and supporting documents from each beneficial owner and keep them on file.
  3. Find the applicable period under Resolución Nº 000168-2025/SUNAT, or the period of RUC registration for companies formed after 30 November 2026.
  4. File Form 3800 in SUNAT Virtual with the Clave SOL, attaching the chain files where required.
  5. File an updated declaration whenever beneficial owners change, within the periods in the regulation.

Common traps

  • Indirect holdings count: 10 percent anywhere up the chain, multiplied through, can make an individual a beneficial owner.
  • If nobody passes the ownership or control tests, the senior manager must be declared; a blank declaration is not an option.
  • Notaries check filing status and report non filers monthly, so a missing declaration can surface during an unrelated deed.
  • Consortia and trusts with a Peruvian trustee are covered as legal arrangements, not only companies.

Sources

Related pages

Related: Peru country profile · live dashboard · central bank and release calendar · our posts on X

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