In effect since May 07, 2019, Peru’s Supreme Decree No. 145-2019-EF established certain parameters in an effort to identify and sanction tax avoidance mechanisms.

The Peruvian general anti-avoidance rule (GAAR) was enacted in 2012; however, through Legislative Decree No. 1121, it was suspended until the issuance of regulations to allow its application.
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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.
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This publication first appeared as a Latin America Alert on www.dlapiper.com.

Several countries in Latin America have established new transfer pricing documentation obligations associated with the OECD’s Base Erosion and Profit Shifting (BEPS) initiative.

In this new year, Mexico, Colombia and Peru have included in their local legislation new documentation requirements that follow a three-tiered approach: country-by-country (CbC) report, master file, and local file. These requirements are based on the revised Chapter V of the OECD’s Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration.  Below is a summary of those requirements.


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The following is a guest post from Bergstein Law in Uruguay

Free Trade Zones (“FTZs”) play a key role in the attraction of foreign investment to Uruguay.  It is estimated that over last decade total accumulated investments in the FTZs amounted to more than USD$5.7 billion, thus becoming one of the main drivers of the Uruguayan economy.

All sorts of activities can be conducted in the FTZs: manufacturing, trade, warehouse, logistics, and services and across all industry sectors of multinationals, including but not limited to soft beverages (PepsiCo), pulp-mills (UPM), asset-managers (Julius Baer), advisory services (the big four included), printing manufacturers (Lexmark), toy industry (Sony) and pharmaceuticals.

Free Trade Zones are specifically delimited areas of the Uruguayan territory in which operations of all types can be conducted at zero tax. FTZsare governed by a legal regime which has been in place for more than 25 years and serve as distribution, trading, logistics, financial and services hub in the region. 
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