ANÁLISIS DE LA FUSIÓN INVERSA ENTRE SOCIEDADES EXTRANJERAS COMO UN SUPUESTO DE ENAJENACIÓN INDIRECTA DE ACCIONES PERUANAS.

Corporate reorganisations carried out by companies incorporated outside Peru do not enjoy a tax neutrality regime. The Peruvian tax authority has stated that, if two foreign companies carry out a reverse merger, the transaction qualifies as a transfer of shares. In this regard, it is therefore necessary to analyse if, in fact, a reverse merger entails the realization of an onerous act between the intervening parties and from which it can be understood that an indirect transfer of shares, subject to Peruvian Income Tax, has occurred. [ABSTRACT FROM AUTHOR]