24 October 2014
On 22 October 2014, the income and capital tax treaty between Romania and Uruguay entered into force. The treaty, signed 14 September 2012, is the first of its kind between the two countries.
The treaty covers Uruguayan tax on business income, personal income tax, non-residents income tax, the tax for social security assistance, and capital tax. It covers Romanian tax on income, tax on profit, and non-residents income tax.
The treaty includes the provision that a permanent establishment will be deemed constituted when an enterprise of one Contracting State furnishes services in the other State through employees or other engaged personnel for the same or connected project for a period or periods aggregating more than 6 months in any 12 month period.
Both countries apply the credit method for the elimination of double taxation.
The treaty applies from 1 January 2015. However, the exchange of information article's provisions will apply regarding criminal tax matters from 22 October 2014.
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