The Latin American Tax Treaties with China
This report highlights and compares the texts of China’s seven bilateral income tax treaties signed and in force with Latin American countries: Argentina (2018), Brazil (1991, amended in 2022), Chile (2015, amended in 2018), Cuba (2001), Ecuador (2013), Mexico (2005) and Venezuela (2001). Of these seven, four were either amended or signed after the conclusion […]
The Latin American Tax Treaties with Germany
This report highlights and compares the texts of Germany’s seven bilateral income tax treaties signed and in force with Latin American countries: Argentina (1978, amended in 1996), Bolivia (1992), Costa Rica (2014), Ecuador (1982), Mexico (2008, amended in 2021), Uruguay (2010) and Venezuela (1995). Of these seven, only one was amended after the conclusion of […]
The BEPS MLI Positions of Colombia and Uruguay
This report outlines the positions taken by two Latin American countries in the OECD’s Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the BEPS MLI). One of them is Colombia, a member of the OECD, and the other is Uruguay, a participant of the OECD/G20 Inclusive Framework. This […]
Tax Liabilities of Payment Processors in LatAm
This report outlines the (current or potential) tax liabilities facing the payment processing industry in Latin America, especially in the context of cross-border transactions. These would include liabilities for collecting VAT, GST or WHT on transactions handled by payment processors as well as joint or subsidiary liability for lack of payment (if they are required, […]
Reinsurance PEs in LatAm Tax Treaties
On July 21, 1959, France and Germany signed a bilateral income tax treaty that bears a striking resemblance to modern-day tax treaties. Its original version had an Article 4th with provisions about business profits, Articles 7th, 9th, 10 and 15 with provisions about taxing rights on capital gains, dividends, interest and royalties, and even an […]
Tax Expenditures in Latin America: A Review
On December 9th, 2024, the OECD published a report titled “Latin American Economic Outlook 2024: Financing Sustainable Development” (LAEO), and it contains a scathing assessment of fiscal policies in the region. As stated by the Organization, tax revenues of Latin American and Caribbean (LAC) countries averaged 21.5% of GDP in 2022, which was considerably lower […]
The Tax Treaties Signed by LatAm Countries in 2024
In 2024, Brazil, Colombia, Cuba, Ecuador and Uruguay signed bilateral income tax treaties (BITTs) and protocols to BITTs with jurisdictions in Europe and in the Middle East, all of which are either members of the OECD or participants of the OECD/G20 BEPS Inclusive Framework. These agreements showcase some of Latin America’s tax policy preferences (and […]