Ultimate Beneficial Ownership of entities with no legal personality: Filing deadline modified

Through Superintendency Resolution No. 278-2022/SUNAT, which was published on December 23, 2022, the Peruvian Tax Authority (SUNAT) modified the deadline to file the declaration of Ultimate Beneficial Owners in the case of entities with no legal personality (Superintendency Resolution No. 000041-2022/SUNAT), which was to be performed in the December 2022 tax period in accordance with the deadlines established based on the last digit of each Tax ID number (RUC).¹

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As a result, entities with no legal personality must declare their Ultimate Beneficial Owners before the deadlines
established for the December 2023 tax period, or their extensions, if applicable, provided that said entities:

are registered in SUNAT’s Taxpayer Registry by December 31, 2023,
are active as of the date when these are required to file the referred declaration.

In that sense, Superintendency Resolution No. 000281-2022/SUNAT, which was published on December 24, 2022,established the schedule to meet monthly tax obligations for year 2023, where the deadlines for the December 2023 tax period are the following:

January 2024 deadlines for the December 2023 tax period
December 2023 tax period	0	1	2 and 3	4 and 5	6 and 7	8 and 9	January 2024 deadlines
January 2024 deadlines	11^th business day	12^th business day	13^th business day	14^th business day	15^th business day	16^th business day	17^th business day

Considering that the filing deadlines have been modified, our suggestion to the managers and administrators of entities with no legal personality who wished to file their declaration in January 2023 is to perform a new analysis at a reasonable date close to the new deadline , as there may be certain changes and/or variations that may require conducting a new analysis in the future.

If you have questions, please contact our Legal Services team:

Carina Dávila, Legal Manager, Business Services & Outsourcing

Miluska Rosales, Corporate Legal Supervisor, Business Services & Outsourcing

Learn more about our BDO Peru legal services.

_{¹For more information on the exact previous deadlines for the 2022 tax year, we suggest referring to our previous publication by clicking here.}

_{The information in this publication is current as of January 6, 2023.

This publication has been carefully prepared, but it has been written in general terms and should be seen as broad guidance only. The publication cannot be relied upon to cover specific situations and you should not act, or refrain from acting, upon the information contained therein without obtaining specific professional advice. Please contact BDO Perú to discuss these matters in the context of your particular circumstances. BDO Perú, its partners, employees and agents do not accept or assume any liability or duty of care for any loss arising from any action taken or not taken by anyone in reliance on the information in this publication or for any decision based on it.}

1For more information on the exact previous deadlines for the 2022 tax year, we suggest referring to our previous publication by clicking here.

_{¹For more information on the exact previous deadlines for the 2022 tax year, we suggest referring to our previous publication by clicking here.}