Obligation to report Ultimate Beneficial Owners: Deadlines and Relevant Considerations


Dear clients,

We would like to remind you that, in accordance with current regulations, legal entities and legal arrangements domiciled in Peru are required to file the Declaration of Ultimate Beneficial Owners to the National Superintendency of Customs and Tax Administration (SUNAT).

Such declaration is considered as an informative declaration, allows identifying the natural person who ultimately owns or effectively controls a company or legal arrangement, and must be filed in in the form, within the deadlines, and under the conditions established by SUNAT.
 

Updated filing deadlines

Superintendency Resolution No. 000168-2025/SUNAT, published in May 2025, approved new deadlines to comply with this obligation. Such deadlines have been established based on the entity’s income from the prior year:

 

Scenarios with deadline through November 2026

On an exceptional basis, legal entities must comply with this obligation by the November 2026 tax period if they fall under any of the following scenarios:

  • They are required to file all determinative declarations.
  • They are not included within the brackets indicated above.
  • They obtained their Tax Identification Number (RUC number) by December 30, 2024, but have not activated it as of that date.
  • They obtain or activate their Tax ID number between January 1, 2025 and November 30, 2026.

In addition, legal arrangements (such as autonomous estates, consortiums, investment funds, among others) registered in SUNAT’s RUC Registry between October 1, 2024, and November 30, 2026, must submit their declaration by the November 2026 tax period.
 

Filing Frequency and Update Obligation

The Declaration of Ultimate Beneficial Owners is filed only once, in accordance with the schedule established by SUNAT. However, whenever changes occur to the information previously declared, the legal entity or legal arrangement must file an updated declaration within thirty (30) business days, calculated from:

  • The day following the signing of the updated Ultimate Beneficial Owner Form, when the information differs from what was previously reported; or
  • The day following the notice sent to the natural person for whom there are reasonable indications of their Ultimate Beneficial Owner status.

 

Specialized Legal Support

At BDO Servicios Legales y Laborales S.A.C., we remain at your disposal to provide legal support in identifying the Ultimate Beneficial Owner, filing the corresponding declarations, and updating the information when required.

For any additional inquiries or coordination, please do not hesitate to contact us at servicioslegales@bdo.com.pe.


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