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Uruguay Issues Ruling on Transfer Pricing Rules for Finance Transactions between a Non-Resident and its Permanent Establishment

25 July 2014

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Approved Changes

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Uruguay

On 18 June 2014, the Uruguayan tax administration issued a ruling concerning the applicability of transfer pricing rules for finance transactions between a non-resident enterprise and its permanent establishment (PE) in Uruguay. Although Uruguay's transfer pricing rules generally apply to finance transactions between related entities,  according to the ruling they do not apply when between a non-resident enterprise and its PE in Uruguay because such transactions do not generate income or deductible expenses for income tax purposes.