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
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 | 3 and 4 | 5 and 6 | 7 and 8 | Good Taxpayers and PSEU 0, 1, 2, 3, 4, 5, 6, 7, 8 and 9 |
| January 2024 deadlines | 11th business day | 12th business day | 13th business day | 14th business day | 15th business day | 16th business day | 17th 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.
Carina Dávila, Legal Services Manager, Business Services & Outsourcing
Miluska Rosales, Corporate Legal Supervisor, Business Services & Outsourcing
1 For more information on the exact previous deadlines for the 2022 tax year, we suggest referring to our previous publication by clicking here.