Uruguay - The New “Transparency Law” and the Implementation of the Base Erosion and Profit Shifting Project on Uruguayan Transfer Pricing Regulations: Theory and Problems to Come
- J. Bonet; A. Galeazzi
- International Transfer Pricing Journal, 2017 (Volume 24), No 5
- 4 September 2017
In order to align with the standards of the OECD BEPS Action Plan, in particular with Action 13 on transfer pricing (TP) documentation, but also with Actions 8-10, aimed to ensure that TP outcomes are in line with value creation, Uruguay has passed a law (effective for fiscal years beginning on or after 1 January 2017), which incorporates the country-by-country (CbC) report and the Master File into the current TP regulations. This article will describe the new regulations and the Uruguay TP status and will discuss how the new law in force creates several interpretation issues which may create future mismatches when interacting with other jurisdictions.