(Pontificia Universidad Católica del Perú, 2016) Cores Ferradas, Roberto; Valdez Ramírez, Víctor
In this article, the authors explain the type of treatment the Call Spread options should be given. They argue that these should be treated as a unique derivative and not as one compound by two independent elements. Likewise, they outline the premium as an inherent element in the determination of any gains or losses from the financial options that it is decided to adopt. As an important point, they claim that adopting one specific side about the treatment of the Call Spread options and the premium implies having a viewpoint about their determination in the Income Tax.
(Pontificia Universidad Católica del Perú, 2016) Tartarini Tamburini, Tulio
This article addresses the subject of secondary adjustment on transfer pricing, focusing on its nature and its regulation in Peru. To do this, the author explains the concept and purpose of transfer pricing and also elaborates some terminological precisions concerning adjustments on transfer pricing, defining the primary adjustments, the compensating ones, the correlative ones and, in more depth, the secondary ones. Likewise, the author explains the way secondary adjustments of transfer prices are regulated by the Peruvian Income Tax Law.
(Pontificia Universidad Católica del Perú, 2016) López Saldaña, Cesar
The objective of this article is to analyze, from a tax perspective some aspects arising from the secondment, such as the possible double residence of the employees assigned, the application of income tax on income from personal servicedependent on light model Convention for the Avoidance of Double Taxation of the Organization for Economic Cooperation and Development (“OECD CDI”) and the possible establishment of a permanent establishment by assigning employees to the State of destination.
