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Uruguay’s Tax Authority clarifies tax treatment of profit repatriations paid by a permanent establishment under double tax treaty

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Uruguay

  • The Uruguayan Tax Authority (Dirección General Impositiva, DGI) has confirmed that profit repatriations received by the head office from its permanent establishment (PE) in Uruguay are not subject to nonresident income tax (NRIT).

In Consultation No. 6490, Uruguay’s DGI concluded Article 7 (Business Profits) of the Uruguay-Belgium double tax treaty applies to profit repatriations from a PE to its h…

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