Peru Issues New UBO Filing Deadlines Under Resolution No. 000168-2025/SUNAT
The Superintendencia Nacional de Aduanas y de Administración Tributaria (SUNAT) has set new deadlines for Ultimate Beneficial Ownership (UBO) affidavits, with phased compliance running from October 2025 to November 2026. All Peru-domiciled entities must comply or face penalties of up to 0.6% of net income.
SUNAT has announced new deadlines
for filing Ultimate Beneficial Ownership (UBO) affidavits, further extending Peru’s framework for corporate transparency.
Resolution No. 000168-2025/SUNAT, published on 28 May 2025, introduces updated filing requirements for an additional group of taxpayers. This resolution reinforces SUNAT’s broader objective of gradually expanding UBO reporting across all relevant legal entities in Peru.
Background
Peru first introduced UBO disclosure rules in 2019, marking a significant step in aligning with international standards on corporate transparency and anti-money laundering (AML). These rules were expanded in 2022, as part of SUNAT’s strategic roadmap to improve the detection of illicit financial activity and prevent the misuse of corporate structures.
The 2025 resolution represents the next phase in this rollout, establishing a systematic and phased approach to bring nearly all Peru-domiciled entities into the UBO reporting regime.
Applicability and Deadlines
The new obligations apply to legal entities domiciled in Peru that were not already included in the earlier deadlines (2019, 2022). Deadlines are phased according to net income reported for Fiscal Year 2024, measured in Tax Units (UIT):
| Income Bracket (UIT) |
Approx. Value in PEN |
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:
-
Legal entities not included in the above brackets or not required to file annual or monthly returns for FY2024.
-
Entities that activated their RUC (Taxpayer ID) up to December 2024, or registered between January 2025 and November 2026.
-
Legal arrangements established in Peru and registered in the RUC during October 2024–November 2026.
Entities registering after November 2026 must comply with deadlines applicable to the period in which they register or activate their RUC.
Definition of UBO
An Ultimate Beneficial Owner (UBO) is defined as:
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An individual who ultimately owns or controls legal entities or arrangements, directly or indirectly.
-
An individual on whose behalf a transaction is carried out, or who exercises ultimate control over a client.
This definition includes ownership through chains of entities, indirect control, or other mechanisms of influence.
Required Actions
To comply with the updated resolution, entities should:
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Determine applicability – Assess whether your entity falls under the new brackets.
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Identify UBOs – Map out ownership/control structures to identify ultimate beneficial owners.
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Prepare and file the affidavit – Ensure submissions are made in line with SUNAT’s deadlines.
Why This Matters
UBO disclosure is part of a global trend toward greater corporate transparency, driven by the Financial Action Task Force (FATF) and adopted across multiple jurisdictions. By enforcing these rules, Peru is positioning itself as a stronger player in combating money laundering, tax evasion, and corruption.
For multinational groups with operations in Peru, this means additional compliance layers — but also improved credibility in the global marketplace.
How Cresco Can Support You
Cresco assists businesses with navigating regulatory complexity across borders, including UBO reporting obligations. Our experts ensure that your entity remains compliant with SUNAT’s requirements while minimizing administrative burden.
For tailored guidance on Peru’s new UBO deadlines, contact info@cresco-global.com
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