On 7 February 2018, the Peru tax authority (SUNAT) published Report No. 097-2018-SUNAT/7T0000 concerning the inclusion of controlled foreign company (CFC) income in cases where the CFC of a taxpayer is a holding company that in turn holds other CFCs. The report clarifies that in such cases, the net passive income of CFCs should not be consolidated for the purpose of attributing the income to P…