The CFC rules apply to domiciled taxpayers who own non-domiciled controlled entities with respect to their passive income, provided that they are subject to income tax in Peru for their foreign-source income.

The Peruvian taxpayer must include the net passive income obtained by the CFC as taxable income at the end of the fiscal year. It is irrelevant whether such passive income has actually been distributed by the CFC. The income attribution regime does not include passive income already taxed in Peru as Peruvian-source income; the tax already paid abroad by the CFC can be credited against the Peruvian taxpayer's tax liability.