On October 24, 2012 Uruguay entered into a Tax Information Exchange Agreement with Brazil (“the TIEA”). The TIEA is yet to be ratified by both Congresses in order to become effective.
Under the TIEA the Contracting Parties undertake to cooperate with each other through the exchange of any information which might be foreseeably relevant for the administration, application, control, enforcement, liquidation and assessment of taxes.
The information to be exchanged under the TIEA is comprehensive and includes any data, statement or document of any type.
Taxes encompassed within the scope of the TIEA are all federal taxes (in the case of Brazil) and all national taxes (in the case of Uruguay).
The Requested Party is required to conduct all administrative or judicial proceedings which may allow the Requested Party to obtain and deliver the requested information.
Fishing expeditions may be denied by the Requested Party.
Inspections by the Tax Office of either country in the other country are allowed, with the prior approval of the Requested Party and in the manner to be previously coordinated with the Requested Party.
The TIEA will enter into force 30 days counted as from the exchange of notices (between the Contracting Parties) confirming that the TIEA has been enacted in accordance with respective local rules. The TIEA will apply to (i) any tax crimes occurring after the effective date, and (ii) fiscal periods starting as from the effective date.
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