PERU Trends and Developments Contributed by: Camilo Maruy, Maite Colmenter, Roberto Polo and Llanet Gaslac, Rebaza, Alcázar & De Las Casas
The income generated from the donated assets will only be taxed in Peru once it is distributed to Peruvian tax residents. Conclusion More than a decade after their implementation in Peru, the CFC Rules have successfully addressed income tax deferral and discouraged the use of low-tax juris - dictions for passive income accumulation. However, their application continues to raise significant legal, technical, and practical challenges. The broad inter - pretation of NDCEs, rigid presumptions regarding passive income, and restrictions on recognising for - eign tax credits have led to concerns about legality, fairness, and economic double taxation, thereby high - lighting the need for regulatory refinements.
475 CHAMBERS.COM
Powered by FlippingBook