In Decree No. 21/021, Uruguay’s Executive Power modifies the requirements taxpayers must meet to not consider goodwill in mergers or spin-offs that are part of a corporate restructuring.
The decree modified the requirements companies must meet to not consider goodwill for tax purposes in corporate restructurings. Under the decree, goodwill will not be considered if:
- The ultimate beneficial owners (UBOs) of the companies participating in the deal remain in the structure, maintaining at least 5% of …