The Peru tax authority (SUNAT) recently published Report No. 138-2020-SUNAT/7T0000 concerning the application and scope of the obligations to report information on ultimate beneficiaries. This includes clarification on who is considered the ultimate beneficiary in certain cases. Some of the main clarifications are as follows: Associations - given the impossibility of identifying the ultimate beneficiary of an association under the ownership criterion or under the control criterion, the ultimate beneficiary is based on the senior administrative (management) position criterion, by virtue of which each of the members of the board of directors or assembly of associates (members) is considered an...