Peru: Tax Amnesty Clarified

On October 10, 2017, clarification regarding Peru’s tax amnesty regime was published, with the following points:

• Foreign-sourced income is not eligible for benefits under the tax amnesty regime and some taxpayers have erroneously included such within the income tax return.
• Controlled foreign companies (CFCs) that are declared conduit entities may apply the tax amnesty regime to all their income if the following criteria are met:
• The taxpayer is declared as a conduit entity with the Peruvian tax authority
• Assets of the CFC that are transferred to the taxpayer may apply for the regime and if the assets that existed as at December 31, 2015, are still owned by the taxpayer's CFC at the time of applying for the regime. It should be noted that such an asset transfer is not considered a taxable event.