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Uruguay’s tax authorities update list of low- or no-taxation countries and jurisdictions and aligns it with the transfer pricing list

03 February 2020

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Tax Alerts, Legislation & Policy, National/Federal Taxation, Transfer Pricing

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Uruguay

In Resolution No. 001/2020 (effective 1 January 2020), Uruguay’s tax authorities align the list of low- or no-taxation (LONT) countries and jurisdictions with the transfer pricing (TP) list so that one list applies for TP and other tax purposes.BackgroundUnder Decree No. 393/019, countries and jurisdictions will be considered LONT for TP purposes when the following conditions are met:An effective tax rate of less than 12% applies to income from activities performed, goods situated (e.g., real estate), or rights economically carried out (e.g., rights to use a brand) in UruguayThe country or jurisdiction has one of the following with Uruguay:An information...