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Practical Handbook for Companies 2021

Transactions with non-cooperative jurisdictions

The article 15 g) of the LIS establishes the non-deductibility of service expenses corresponding to transactions carried out directly or indirectly with persons or entities resident in countries or territories classified as non-cooperative jurisdictions, or which are paid through persons or entities resident in these, unless the taxpayer proves that the accrued expense corresponds to a transaction or operation effectively carried out.

Filling in form 200

In application of the provisions of this provision, the taxpayer must make the following adjustments in boxes [00341] and [00342] "Transactions carried out with non-cooperative jurisdictions (art. 15 g) LIS)" on page 12 of form 200:

  • In the tax period in which these non-deductible expenses are booked, a positive adjustment must be made to the accounting result in box [00341].

  • However, if in subsequent tax periods, the taxpayer proves that these accrued expenses relate to a transaction actually carried out, these expenses will be considered tax deductible and a negative adjustment should be made in box [00342].