Residence in non-cooperative jurisdiction

Regulation: Article 100.13 LIS

When the investee entity or the permanent establishment is located in a country or territory qualified as a non-cooperative jurisdiction, it will be presumed that:

1. The circumstance provided for in letter b) of article 100.1 of the LIS is met.

2. The income of the investee entity meets the characteristics of article 100.3 of the LIS.

3. The income obtained by the investee entity is 15 percent of the acquisition value of the participation.

The presumptions contained in the previous letters will admit evidence to the contrary.