First APA in South America just signed in Uruguay

Tax Insights ()

PwC Uruguay participated in the first Unilateral Advance Pricing Arrangement (APA) in Uruguay. This is the first ever APA completed in South America. PwC acted as advisors for the project, assisting with all aspects of the negotiation and conclusion of the APA.

Under the current regulations, the Uruguayan Tax Administration may celebrate APA with taxpayers for a period of three fiscal years. Although, the regulatory rules states that the Tax Administration will establish the conditions and formalities required for subscribing an APA, these detailed regulations have not been issued up to this moment. It is expected that this leading case constitutes the base under which such new rules will be issued.