Considerations for the application of the 15% income tax reduced rate on services rendered by nonresident companies

Tax Court Resolution Nro. 00663-2-2023 analyzes the arguments raised by the tax authorities and a resident withholding agent concerning the application of the tax definition of "technical assistance" to certain services rendered by nonresident companies, and confirms the assessment made by the former as the activities do not meet the conditions established in the law. This ruling is relevant as it highlights certain essential conditions that must be present when seeking to apply the 15% withholding rate on the grounds of technical assistance services rendered.