February 3, 2020
Uruguay’s tax authorities update list of low- or no-taxation countries and jurisdictions and aligns it with the transfer pricing list
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.
Under Decree No. 393/019, countries and jurisdictions will be considered LONT for TP purposes when the following conditions are met:
These conditions align the TP rules with the LONT criteria that applies for other tax purposes.
The decree also required the tax authorities to prepare a list of countries and jurisdictions that would qualify as LONT. The list appears in Resolution 001/2020.
Resolution No. 001/2020
The following 40 countries and jurisdictions are on the list:
The Resolution allows countries or jurisdictions on the list to be removed, provided certain conditions are met:
For additional information with respect to this Alert, please contact the following:
Ernst & Young Uruguay, Montevideo
Ernst & Young LLP (United States), Latin American Business Center, New York
Ernst & Young LLP (United Kingdom), Latin American Business Center, London
Ernst & Young Tax Co., Latin America Tax Desk, Japan & Asia Pacific