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Uruguay modifies when goodwill is not considered in corporate restructurings

11 February 2021

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Tax Alerts, Legislation & Policy, National/Federal Taxation

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Uruguay

In Decree No. 21/021, Uruguay’s Executive Power modifies the requirements taxpayers must meet to not consider goodwill in mergers or spin-offs that are part of a corporate restructuring.The decree modified the requirements companies must meet to not consider goodwill for tax purposes in corporate restructurings. Under the decree, goodwill will not be considered if:The ultimate beneficial owners (UBOs) of the companies participating in the deal remain in the structure, maintaining at least 5% of their equity proportions, and the UBOs are not modified for at least two years from the date of the merger or spin-off agreement.The affidavit filed before...