News published in INFORMA 2022
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145139-CAPITALIZATION RESERVE. DISSOLUTION BEFORE THE TERM UNAVAILABILITY OF THE RESERVATIONIf an entity were to be dissolved before the 5-year period had elapsed, there would be a breach of the requirement to maintain the unavailable reserve, which would give rise to the corresponding adjustment of the improperly reduced amounts.
145138-CAPITALIZATION RESERVE MAINTENANCE TERM COMPUTATIONThe provision of a reserve for the amount of the reduction made must appear on the balance sheet with absolute separation and appropriate title, and will be unavailable for the period of 5 years from the close of the tax period to which the reduction corresponds.
145140-DEDUCTIBLE EXPENSES. REMUNERATION TO NON-RESIDENT PARTNERAny accounting expense will be a tax-deductible expense for the purposes of Corporate Tax, however, letter g) of article 15 of the LIS determines that service expenses corresponding to operations carried out, directly or indirectly, with persons or entities resident in countries or territories qualified as tax havens , or that are paid through persons or entities resident in these, will not be considered tax-deductible, except that the taxpayer proves that the accrued expense responds to an operation or transaction actually carried out.