The Peruvian income tax law states that corporate taxpayers will be able to deduct royalties and payments for services made to non-residents in the tax year in which the payment is effectively made to the nonresident, regardless of whether the royalty or the service payment was recognised in a different tax year.
The Peruvian Tax Administration, by means of Report No. 130-2019-SUNAT/7T0000, has stated that the above-mentioned rule is applicable for the payment of interest to non-domiciled entities.
Thus, the Peruvian borrower will be entitled to deduct the interest only during the fiscal year in which the interest is effectively paid to the non-resident lender.
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