Estonian Company Run from Peru: Tax Rules

Some entrepreneurs who live in Peru form or buy an Estonian private limited company (OÜ), often as e-residents, and run it from Lima or Cusco. That works, but Peruvian income tax does not stop at the border: a place of management in Peru of a foreign company is a permanent establishment, and Peruvian residents who own more than half of a low-taxed foreign company are taxed on its passive income. Estonia and Peru have no tax treaty. This guide sets out these rules with the official text, and what we do on the Estonian side.

The guide is general information, not tax advice. How your company and you are taxed depends on the facts of your case; ask a Peruvian tax adviser before you form or buy the company. We read the Income Tax Law (Ley del Impuesto a la Renta) in the updated text published by SUNAT, the Peruvian tax authority, with amendments published up to 31 December 2025, and the Estonian Ministry of Finance's list of tax treaties, on 24 October 2026.

In Estonia: an Estonian company is Estonian

A company established under Estonian law is resident in Estonia for tax purposes (Income Tax Act § 6). Its profit is taxed when it is distributed, not while it stays in the company — the guide how Estonia taxes company profit explains the rule. The company keeps its Estonian duties wherever its owners live: accounts, an annual report to the commercial register and, if its address is abroad, a contact person in Estonia.

In Peru: the company side

Domiciled companies are those formed in Peru. Legal persons constituted in Peru are domiciled there (Income Tax Law, article 7(d)), and domiciled taxpayers are taxed on all their income wherever it arises, regardless of where a legal person was constituted (article 6).
A place of management is a permanent establishment. A permanent establishment is any fixed place of business through which an entity constituted abroad carries on all or part of its activities, and places of management are named among them (article 14-B(1)).
What a permanent establishment pays. A permanent establishment in Peru of an entity constituted abroad is domiciled for its income from Peruvian sources (article 7(e)), and on that income alone (article 6).
Rate. Domiciled recipients of business income pay 29.5 per cent of their net income (article 55).

An Estonian OÜ is not a Peruvian company. If you live in Peru and manage the business from there, Peru can treat that place of management as a permanent establishment of the Estonian company and tax its income from Peruvian sources. Your Peruvian tax adviser answers that with the facts of your case.

In Peru: the owner side

Who is a resident individual. Peruvian nationals with their domicile in Peru are domiciled taxpayers, and so are foreign nationals who have resided or stayed in Peru for more than 183 calendar days in any period of 12 months (article 7(a) and (b)).
Controlled foreign company rule. Passive income of a controlled foreign entity is attributed to its domiciled owners (articles 111 and 113). An entity is controlled when domiciled taxpayers, alone or with related domiciled parties, hold more than 50 per cent of its capital, results or votes, and it is in a non-cooperative or low or no tax territory, or its passive income is not taxed or is taxed at 75 per cent or less of the Peruvian income tax on income of the same kind (article 112). Dividends are among the passive income the rule names (article 114).

An Estonian company pays no income tax on profit it retains. If its owner lives in Peru and its income is passive, the rule can attribute that income to the owner. Your Peruvian tax adviser answers that with the facts of your case.

No tax treaty between Estonia and Peru

No treaty. Peru is not on the Estonian Ministry of Finance's list of tax treaties in force, signed or initialled.
What that means. There is no treaty rule on a permanent establishment or on the tax on dividends and board fees — each country applies its own law. See board member fee or dividend from abroad for the Estonian side.

What to decide before you form or buy the company

Where the business is managed. A place of management in Peru is a permanent establishment.
What the company earns. Passive income of a company owned from Peru can be attributed to its owners there.
How profits reach you. Without a treaty, each country applies its own rules to dividends and board fees.

What we do on the Estonian side

for your own company, a written analysis of its tax residence and permanent establishment under these rules — an analysis, not tax advice;
online formation for an e-resident — €950 Registered address and contact person service for one year are included., or formation by power of attorney — €1,250;
a ready-made company bought remotely — €1,200 Registered address and contact person service for one year are included.;
accounting — from €150 / month and the annual report — from €450;
the registered address and contact person after the first 12 months — €350 / year.

Our accounting covers the Estonian company's Estonian obligations. Peruvian tax returns and Peruvian tax advice are not included. Owners in other countries: Estonian company run from abroad compares the rules side by side.

Prices exclude VAT. All communication takes place by email.

Ready to start? A new Estonian company — online for e-residents or by power of attorney; Peruvian tax advice is not included. Order.

Official sources

The laws this article names, by the name of their official text, as read on 9 October 2026. For the Estonian acts we read the English translation in Riigi Teataja; the legally binding text is the Estonian one.

Income Tax Act — Riigi Teataja, English translation

Sources are named in the text, without links. To see which of our services your company needs, open the Business Navigator.

Frequently asked questions

Is my Estonian company taxed in Peru if I run it from Peru?

It can be. Only companies constituted in Peru are domiciled there, but a place of management in Peru of an entity constituted abroad is a permanent establishment (Income Tax Law, article 14-B), domiciled and taxed on its income from Peruvian sources (articles 6 and 7(e)) at 29.5 per cent (article 55). Domiciled owners of more than 50 per cent of a low-taxed foreign company can be taxed on its passive income (articles 111 to 114). In Estonia the company stays resident because it was established under Estonian law (Income Tax Act § 6). Estonia and Peru have no tax treaty, so each country applies its own law. Ask a Peruvian tax adviser before you form or buy the company; we handle the Estonian side.

Estonian company run from Peru: what is taxed where