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UPDATE STATUS

INTRODUCTION

FORMS OF DOING BUSINESS

Main Forms of Doing Business with a Legal Presence

Main Forms of Doing Business

FORMATION

Main Formation Requirements

CORPORATE RESIDENCE

Corporate Tax Residence

PERMANENT ESTABLISHMENTS

Domestic PE of a Foreign Entity

PE-Risk Grid for Foreign Entities Involved in Business Activities

Branch Profit (Deemed Remittance) Tax

TAX BASE

Tax Base for Resident Entities

Treatment of Foreign Profits / Losses

Tax Consolidation / Group Treatment

Tax Base for Non-Resident Entities

Source Rules with Respect to Income Derived by Non-Residents

Qualification of Specific Income Categories for Tax Purposes

DETERMINATION OF TAXABLE INCOME

Main Differences between Commercial and Tax Accounting

Depreciation and Amortization

Deduction of Cross-Border Payments and Non-Deductible Expenses

Taxation of Foreign-Source Income

LOSSES

General Rules

TAX RATES

Residents

Corporate Income Tax

Other Taxes

Non-Residents

Corporate/Profit Taxes

Withholding Taxes

ELIMINATION OF DOUBLE TAXATION

Unilateral and Treaty Based Methods Available for the Elimination or Mitigation of Double Taxation

INCENTIVES AND SPECIAL REGIMES

Specific Incentives

BUSINESS TRANSFORMATION AND RE-ORGANIZATION

Acquisition and Exit Strategies

VAT ON INTERNATIONAL TRANSACTIONS

VAT on the Supply of Goods by Non-Residents

VAT on the Supply of Services by Non-Residents

Refund of VAT to Non-Residents

BASE PROTECTION AND ANTI-AVOIDANCE MEASURES

GAAR and General Anti-Avoidance Measures

Thin-capitalization and other Restrictions to Interest Deduction

Main Rules

CFC and Similar Regimes

Transfer Pricing

Specific TP Issues

Documentation Requirements

APAs and Dispute Resolution Mechanisms

Other Anti-Avoidance Rules

TAX MANAGEMENT AND COMPLIANCE

Books and Records

Type of Assessment

Calendar of Important Compliance Events

Tax Audits

Audit Process

Statute of Limitations

Interest and Penalties

Interest Compensation for Overpayment of Tax

Appeal Procedures