Residence in non-cooperative jurisdiction
Regulation: Article 100.13 LIS
When the participating entity or permanent establishment is located in a country or territory classified as a non-cooperative jurisdiction, it presumed that:
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The circumstance provided for in letter b) of article 100.1 of the LIS is met.
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The income of the participating entity meets the characteristics of article 100.3 of the LIS.
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The income obtained by the participating entity is 15 percent of the acquisition value of the participation.
The presumptions contained in the preceding letters will admit proof to the contrary.