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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 Force of Attraction Principle
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 Rules Governing the Determination of Taxable Income
Main Differences between Commercial and Tax Accounting
Depreciation and Amortization
Reserves and Provisions
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
Holding Regimes
Specific Incentives
BUSINESS TRANSFORMATION AND RE-ORGANIZATION
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
Interest and Penalties
Interest Compensation for Overpayment of Tax
Appeal Procedures
