The Uruguay Government has submitted to Congress a tax bill including adoption of the OECD’s recommendations for Country-by-Country (CbC) reporting following the scope of information to be provided under the Base Erosion and Profit Shifting (BEPS) Action 13 final report. It is expected that this tax bill will be passed before the end of the current legislative period (December 15) and will apply to accounting years starting on or after January 1, 2017.
According to the Bill the master file should provide information of the group regarding organizational structure, activities performed, functions developed, assets used, and risk assumed by the entities of the multinational group, intangible assets, intercompany financing and financial and tax information
The proposed draft law would also allow tax payers to apply for bilateral and multilateral APAs.
