REPORTS

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

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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

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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

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