Tax Alert - August 2026
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Themes
Ultimate Beneficial Owner Declaration
The regime seeks to identify the natural persons who qualify as ultimate beneficial owners of legal entities domiciled in Peru, Peruvian branches, and certain legal arrangements.
Reporting entities must follow a due diligence procedure to support the identification of their ultimate beneficial owners.
They must file a declaration with SUNAT containing the relevant information on their ultimate beneficial owners within the applicable deadlines.
Criteria
Natural persons qualify as ultimate beneficial owners if they fall within any of the following categories:
- Ownership: A natural person who, directly or indirectly, through any means, owns at least ten percent (10%) of the capital of a legal entity.
- Control: A natural person who exercises control over the legal entity, directly or indirectly, through the power to appoint or remove its management bodies, decision-making authority over material resolutions, or any other form of control.
- Senior Management Position: As a residual criterion, the natural person who holds the senior management position of the legal entity.
The ownership and control criteria must be assessed concurrently, meaning that ultimate beneficial owners may be identified under either or both criteria simultaneously. The senior management position criterion is residual and applies only when it is not possible to identify ultimate beneficial owners based on the ownership or control criteria.
Reporting Entities
The obligation to file the ultimate beneficial owner declaration must generally be fulfilled only once, in accordance with the filing schedules approved by SUNAT. A new declaration is required only when changes occur to the information previously reported.
The inclusion of reporting entities within the regime has been implemented gradually. To date, the following filing schedules have been approved:
- Superintendence Resolution No. 000185-2019/SUNAT: legal entities domiciled in Peru that qualified as national principal taxpayers as of November 30, 2019.
- Superintendence Resolution No. 000041-2022/SUNAT: legal entities domiciled in Peru based on the following levels of net income: (i) more than 1,000 UIT; (ii) between 500 and 1,000 UIT; and (iii) more than 300 UIT.
- Superintendence Resolution No. 000168-2025/SUNAT: legal entities domiciled in Peru, according to the following schedule:
The final stage is not subject to any minimum threshold. On the due dates for monthly tax obligations corresponding to November 2026, all legal entities domiciled in Peru that were not included in the previous stages will be required to file the ultimate beneficial owner declaration.
During the same period, legal arrangements established in Peru and registered with the RUC between October 1, 2024 and November 30, 2026 will also be required to file the ultimate beneficial owner declaration.
Recommendations
The ultimate beneficial owner declaration must be filed within the applicable period, in accordance with the filing schedules approved by SUNAT.
If the declaration was not filed by the applicable due date, it is recommended to regularize the obligation as soon as possible.
Failure to file the ultimate beneficial owner declaration, as well as filing an incomplete declaration or providing false information, constitutes a sanctionable infringement subject to a fine equivalent to 0.6% of net income, capped at 50 UIT.
If the infringement is voluntarily remedied before being detected by SUNAT, the penalty may qualify for the gradual penalty reduction regime, with a reduction of up to 100% of the fine.