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 concessions) in relation to external partners. As explained below, they follow the OECD Model Convention (with a few clauses borrowed from the UN Model Convention), even though only one of the five LatAm countries on the list – Colombia – is currently a member of the OECD. Cuba and Ecuador are not even listed in the BEPS Inclusive Framework.
