The Internal Revenue Service issued the Circular
NAC-DGECCGC22-00000012 on December 19, 2022, to clarify the
application over time of the deductibility limit applicable to
expenses for royalties, technical, administrative, and consulting
services paid to related parties (hereinafter the
"Deductibility Limit").
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Background
The President of the Republic issued the Executive Decree 304
published in the Second Supplement of the Official Gazette 608 of
December 30, 2021, which contained the Regulations to the Law of
Economic Development and Fiscal Sustainability after the COVID 19
Pandemic by means of. Said regulations eliminated the Deductibility
Limit established in article 28 #16 of the Internal Tax Regime Law
Regulations.
