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Peru – UBO Affidavit Deadline Update
The Superintendencia Nacional de Aduanas y de Administración Tributaria (SUNAT) has established new deadlines for submitting Ultimate Beneficial Ownership (UBO) affidavits for an additional group of taxpayers.
Resolution No. 000168-2025/SUNAT, published on the 28th of May 2025, outlines these updated submission requirements as part of SUNAT’s ongoing effort to implement comprehensive UBO reporting across Peru.
Background
This initiative, which began in 2019 and was further developed in 2022, is part of SUNAT’s strategic plan to enhance transparency in business ownership and strengthen anti-money laundering measures.
The resolution specifically addresses declaration requirements, demonstrating SUNAT’s commitment to a gradual and systematic approach in implementing UBO reporting obligations across all relevant business sectors in Peru.
Applicability and Deadlines
The new requirements apply to legal entities domiciled in Peru. For those not included in the deadlines established in 2019 or 2022, the obligation to submit the declaration in this new phase is organized by brackets based on the net income reported for Fiscal Year 2024:
| Income Bracket (in Tax Units – UIT) | Deadline |
|---|---|
| More than 100 UIT (PEN 515,001 and above) | October 2025 |
| 50 – 100 UIT (PEN 257,501 – PEN 515,000) | December 2025 |
| 25 – 50 UIT (PEN 128,751 – PEN 257,500) | July 2026 |
| 10 – 25 UIT (PEN 51,501 – PEN 128,750) | September 2026 |
| Up to 10 UIT (up to PEN 51,500) | November 2026 |
The November 2026 deadline also applies to:
- Domiciled legal entities not included in the above brackets or not required to file annual income tax returns or monthly returns for fiscal year 2024.
- Entities that activated their Taxpayer ID (RUC) up to December 2024 or registered between January 2025 and November 2026.
- Legal arrangements established in Peru and registered in the RUC from October 2024 to November 2026.
Entities registering after November 2026 must submit the declaration according to the deadlines applicable to the period in which they register or activate their RUC.
Definition of UBO
An ultimate beneficial owner is defined as:
- An individual who effectively and ultimately owns or controls legal entities or legal arrangements.
- An individual who ultimately controls a client or on whose behalf a transaction is carried out.
“Ultimate ownership or control” refers to situations where ownership and/or control is exercised through a chain of ownership or by any other means of indirect control.
Actions Required
1. Assess your company’s obligation to submit the UBO declaration based on the new income brackets and deadlines.
2. Identify your ultimate beneficial owners according to the provided definition.
3. Prepare and submit the UBO affidavit by the applicable deadline.
The Risks of Non-Compliance
Failure to comply with UBO identification and reporting obligations constitutes an infraction subject to penalties.
Fines range from 0.6% of net income (not less than 5 UIT and not more than 50 UIT) to 0.3% of net income (not less than 3 UIT and not more than 25 UIT).
How Mercator® by Citco Can Help
Mercator can assist with the necessary process of filing UBO affidavits in compliance with these new requirements.
Contact mercator@citco.com for more information.
