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Withholding tax on payments abroad from Peru: dividends, interest, royalties, technical assistance, services and the deductibility link

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

Whoever pays Peruvian source income to a non domiciled person must withhold the final tax and pay it to SUNAT with the monthly filings. Rates for foreign companies are 5 percent on dividends, 4.99 percent on qualifying loan interest, 15 percent on technical assistance, 10 percent on ship and aircraft rental and 30 percent on royalties, related party interest, services and other income, generally on the gross amount. Treaties can cut the royalty and interest rates to 10 or 15 percent, and the payment must be made by the annual return due date for the expense to stay deductible.

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, from the Banco Central de Reserva del Perú statistics series PD04640PD. UIT based amounts use the 2026 UIT of S/ 5,500 set by Decreto Supremo Nº 301-2025-EF. Conversions are for orientation only.

Key facts

Withholding on dividends paid to non domiciled shareholders5 %LIR art. 56 e) (DL 1541), as of 2026-10-28 · in force
Withholding on qualifying foreign loan interest4.99 %LIR art. 56 a), as of 2026-10-28 · in force
Withholding on interest paid to related foreign lenders30 %LIR art. 56 j), as of 2026-10-28 · in force
Withholding on royalties paid abroad30 %LIR art. 56 d), as of 2026-10-28 · in force
Withholding on technical assistance paid abroad15 %LIR art. 56 f), as of 2026-10-28 · in force
Withholding on other services and income paid to foreign companies30 %LIR art. 56 j), as of 2026-10-28 · in force
Withholding on ship and aircraft rental10 %LIR art. 56 c), as of 2026-10-28 · in force
Contract value above which an audit report is required for technical assistance140 UITLIR art. 56 f), as of 2026-10-28 · in force

The rule

1. Any person or entity that pays or credits Peruvian source income of any kind to a non domiciled beneficiary must withhold the tax under art. 54 (individuals) or art. 56 (legal entities) as a final tax and pay it to SUNAT within the deadlines for monthly obligations. For the withholding, the gross amount paid is the net income, except presumptive percentages for the activities in art. 48 and deduction of invested capital on sales of assets.Texto Único Ordenado de la Ley del Impuesto a la Renta (Decreto Supremo Nº 179-2004-EF), Art. 76 first and second paragraphs, letters a) to g), 2004-12-08 official text · verified 2026-10-28
2. Rates on non domiciled legal entities: interest on foreign loans 4.99 percent when cash loans bring foreign currency into Peru and the rate does not exceed the prevailing preferential rate of the lender's market plus 3 points; interest on credit lines used by Peruvian banks 4.99 percent; ship and aircraft rental 10 percent; royalties 30 percent; dividends and other profit distributions 5 percent; technical assistance 15 percent; live shows 15 percent; gains on securities sold within Peru 5 percent; interest on bonds and deposits 4.99 percent; and 30 percent on all other income, including interest paid to a related foreign lender or through a lender used to disguise a related party loan.Texto Único Ordenado de la Ley del Impuesto a la Renta (Decreto Supremo Nº 179-2004-EF), as amended by Ley Nº 29645, Decreto Legislativo Nº 1120 and Decreto Legislativo Nº 1541, Art. 56 letters a) to j), 2022-03-26 official text · verified 2026-10-28
3. For technical assistance taxed at 15 percent, the Peruvian user must obtain and give SUNAT a report from an audit firm certifying that the assistance was actually provided when the total fee under one contract, including extensions, exceeds 140 UIT at the date the contract is signed (S/ 770,000 for 2026 contracts).
Cost to do it: Audit firm report fee, required only above 140 UIT per contract.Texto Único Ordenado de la Ley del Impuesto a la Renta (Decreto Supremo Nº 179-2004-EF), letter f) as amended by Decreto Legislativo Nº 1120, Art. 56 letter f), 2012-07-18 official text · verified 2026-10-28
4. Non domiciled individuals bear 5 percent on dividends, on gains from selling real estate and on other capital income; 4.99 percent on interest paid by a Peruvian business that is not related to them (30 percent if related or routed through non cooperative or low tax jurisdictions); 30 percent on gains from selling securities abroad, business income, employment income, royalties and other income; and 15 percent on live performances in Peru.Texto Único Ordenado de la Ley del Impuesto a la Renta (Decreto Supremo Nº 179-2004-EF), as amended by Decreto Legislativo Nº 1258, Decreto Legislativo Nº 1261 and Decreto Legislativo Nº 1381, Art. 54 letters a) to j), 2018-08-24 official text · verified 2026-10-28
5. For certain international activities the law presumes, with no proof to the contrary, a fixed net income as a share of gross receipts, and the 30 percent rate applies to that presumed income: insurance 7 percent of premiums, international air transport 1 percent and sea freight 2 percent, international telecommunications 5 percent, film distribution 20 percent, container supply 15 percent, container demurrage 80 percent, ship rental 80 percent and aircraft rental 60 percent of gross receipts.
Example: Reinsurance premiums of S/ 1,000,000 ceded abroad: presumed income S/ 70,000, tax S/ 21,000 (2.1 percent effective). / Premiums of US$289,687: tax US$6,083.Texto Único Ordenado de la Ley del Impuesto a la Renta (Decreto Supremo Nº 179-2004-EF), Art. 48 letters a) to j), 2004-12-08 official text · verified 2026-10-28
6. Digital services provided over the internet and used, consumed or employed economically in Peru, and technical assistance used economically in Peru, are Peruvian source income even when the provider is abroad, so a Peruvian business paying for them must withhold.Texto Único Ordenado de la Ley del Impuesto a la Renta (Decreto Supremo Nº 179-2004-EF), letter i) as substituted by Decreto Legislativo Nº 970, Art. 9 letters i) and j), 2006-12-24 official text · verified 2026-10-28
7. Royalties and fees for services, technical assistance, rental and similar items owed to non domiciled beneficiaries are deductible in the year they accrue only if they are paid or credited by the due date of that year's annual return; if paid later, they are deducted in the year of payment.Texto Único Ordenado de la Ley del Impuesto a la Renta (Decreto Supremo Nº 179-2004-EF), letter a.4) added by Decreto Legislativo Nº 1369, Art. 37 letter a.4), 2018-08-02 official text · verified 2026-10-28
PaymentRateConditionRule
Dividends and other profit distributions5%Branch profits deemed distributed at the annual return due dateArt. 56 e)
Interest on foreign loans4.99%Foreign currency enters Peru and rate within preferential rate plus 3 points; unrelated lenderArt. 56 a)
Interest to related lenders or disguised related loans30%Any related foreign lenderArt. 56 j)
Royalties30%On gross amountArt. 56 d)
Technical assistance15%Audit report if contract exceeds 140 UITArt. 56 f)
Ship and aircraft rental10%On gross amountArt. 56 c)
Gains on securities sold in Peru5%Registered and traded on a Peruvian centralized mechanismArt. 56 h)
Services, digital services and other income30%Peruvian source income not listed elsewhereArt. 56 j)

Domestic withholding rates on payments to non domiciled companies (LIR art. 56); treaty limits on the tax treaties page

Worked example

  • A Peruvian subsidiary pays its foreign parent a royalty of S/ 100,000 (US$28,969). It withholds 30 percent, S/ 30,000 (US$8,691), and remits S/ 70,000. If the parent is resident in Chile and proves it, the treaty caps the tax at 15 percent, S/ 15,000 (US$4,345).
  • A technical assistance contract worth S/ 900,000 (US$260,718) bears 15 percent, S/ 135,000 (US$39,108); because it exceeds 140 UIT (S/ 770,000) the subsidiary must also obtain an audit firm report.
  • Interest of S/ 200,000 on an intercompany loan from the parent bears 30 percent, S/ 60,000; the same interest paid to an unrelated foreign bank on a qualifying loan bears 4.99 percent, S/ 9,980 (US$2,891).
  • A dividend of S/ 1,000,000 (US$289,687) bears 5 percent, S/ 50,000 (US$14,484), so the parent receives S/ 950,000.

Step by step

  1. Classify each payment (dividend, interest, royalty, technical assistance, service, rental) and check whether the recipient is related.
  2. If a treaty applies, obtain the recipient's tax residence certificate before paying.
  3. Withhold on the gross amount when paying or crediting (including book credits) and pay it with the monthly filing for that month.
  4. For technical assistance above 140 UIT per contract, obtain the audit firm report and keep it for SUNAT.
  5. Pay fees owed to non domiciled parties by the annual return due date so they stay deductible in the year they accrue.

Common traps

  • Interest paid to a related foreign lender is taxed at 30 percent, not 4.99 percent, and the 30 percent EBITDA cap may also disallow the deduction.
  • Crediting an amount in the books (acreditar) is enough to trigger withholding, even without a cash transfer.
  • SaaS and other digital services bought from abroad are Peruvian source income when used in Peru, so the payer withholds 30 percent unless a treaty treats them as business profits.
  • Insurance, freight and film payments use the art. 48 presumptions, which give effective rates well below 30 percent; applying 30 percent to the gross overwithholds.

Sources

Related pages

Related: Peru country profile · live dashboard · central bank and release calendar · our posts on X · where Argentina is involved, see The Argentine Thread guide

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