Uruguay Tax Agency Posts Consultation Clarifying Application of DTA With Spain to Service, Royalty Payments

The Uruguayan General Directorate of Taxation May 8 posted online Consultation No. 6767, clarifying the application of the 2009 DTA with Spain to payments for services and trademark royalties. The taxpayer, a Uruguayan company, sought clarification on taxation for payments from a Spanish entity, for network services and the use of trademarks. The consultation clarifies that: 1) payments for services provided by the Spanish entity are taxable only in Spain, unless the Spanish entity operates through a permanent establishment (PE) in Uruguay; 2) payments for using trademarks are taxable in Uruguay at up to 10 percent, if the Spanish entity ...