CFC is a non-domiciled entity that fulfils the following conditions:(i) It is treated as opaque. It is considered that companies, trusts, investment funds and partnerships always comply with this requirement. (ii) It is incorporated or established in a: non-cooperative or low-tax jurisdiction, or jurisdiction in which its passive income is not subject to an income tax, or jurisdiction in which the tax effectively paid for the entity's passive income is equal or less than 75% of the Peruvian tax which would be payable on the same income. (iii) Peruvian domiciled taxpayer alone or together with its Peruvian domiciled related parties owns directly or indirectly more than 50% of the capital, voting power or the profits of the entity. Options to acquire shares must be considered to determine the test control.