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The global pandemic forced Latin American governments to focus on


Continue Reading Tax Insights: Inaugural Newsletter for LatAm Developments

This is a guest post from our friends at Bergstein Abogados in Uruguay

Uruguay is becoming an increasingly popular jurisdiction for tax residence. This article briefly discusses the new opportunities Uruguay offers for personal income
Continue Reading Uruguay’s tax residence rules – new planning opportunities for foreign individuals

Arbitration is alive and growing in Brazil. According to research conducted among Brazil’s six main arbitral institutions, in 2010 there were 128 new arbitration proceedings; then in 2017, this number jumped to more than 275.
Continue Reading Brazilian federal government issues decree regulating arbitration in disputes between Public Administration and transport and logistics sectors

We are pleased to present an analysis by our guest post this month, Berkemeyer Abogados of Paraguay.

Rutas del Este S.A., Contratista PPP cuyos accionistas son Sacyr (de España) con un 60% y Ocho A (de Paraguay) con el 40%, obtuvo el cierre financiero del proyecto Rutas 2 y 7 que une Asunción con Ciudad del Este. A principios de 2018 el proyecto había tomado un préstamo puente de USD 50 millones con 4 bancos locales, cuya deuda se canceló con fondos del financiamiento de largo plazo, queconstaprincipalmente de dos transacciones:

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Continue Reading Se cierra el financiamiento de la primer PPP de Paraguay

Guest post from Bergstein Law of Uruguay

On June 28, 2019 the European Union and the MERCOSUR group − comprised of Argentina, Brazil, Paraguay and Uruguay − reached a mutual understanding  over a trade agreement. Both sides have been negotiating such an agreement for 20 years. European Commission President Jean-Claude Juncker calls this the largest trade agreement the European Union has ever concluded.
Continue Reading After 20 years of negotiations, EU and MERCOSUR reach understanding on free trade agreement

Guest post from our friends at Bergstein Abogados

Uruguay requires online companies incorporated abroad, with no presence in Uruguay, to pay taxes in Uruguay whenever their clients are located within Uruguayan territory. Online services providers (such as Netflix and Spotify) are subject to VAT at the rate of 22 percent, plus Non-Residents Income Tax (so-called IRNR) at the rate of 12 percent, both assessed over the sales price. Online services intermediaries (such as Airbnb) are subject to the same taxes, except that IRNR is assessed only over 50 percent of their sales where one of the parties of the ultimate transaction (the supplier or end-user) is based abroad.

In May this year, Uruguay’s Executive Branch issued a regulatory decree, summarized below, clarifying aspects of the tax law; and a few days ago, the Tax Office issued a special resolution spelling out certain implementation details.
Continue Reading E-commerce companies: Tax recent developments in Uruguay

The Governments of Brazil and Switzerland have signed the Convention for Elimination of Double Taxation with Respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance (DTT). In line with Brazil’s commitments under the G20, the DTT, signed on May 3, 2018, incorporates certain minimum standards of the Organization for Economic Cooperation and Development (OECD) Project on Tax Erosion and Transfer of Profits (BEPS Project). It also includes an anti-abuse clause as well as an administrative assistance clause in accordance with the current international standard for exchange of information.
Continue Reading Brazil and Switzerland sign Convention for Elimination of Double Taxation – highlights