Tax News in Latin America: A Summary of the 5th Edition of Baker Tilly's LATAM Magazine

The most recent edition of Baker Tilly's “Revista LATAM” magazine, published in December 2025, offers a detailed overview of the tax transformations that are shaping the business environment in Latin America. Through expert analysis, the publication addresses key reforms in Brazil, Colombia, Costa Rica, Guatemala, Paraguay and Uruguay, highlighting a regional push toward modernization, transparency and attracting investment.

Analysis by Country

Below is a summary of the main tax news included in the publication:

Brazil: A significant reform to the Income Tax is introduced with Bill 1,087/2025, which will enter into force on January 1, 2026. Key points include an exemption for individuals with monthly income of up to R$ 5,000, a new 10% withholding rate on the distribution of profits and dividends that exceed certain thresholds, and the creation of a Minimum Income Tax (IRPFM) for individuals with high annual income.

Colombia: With the objective of encouraging the export sector, the government has regulated Tax Refund Certificates (CERT). This instrument, applicable to exports of specific goods and services carried out in 2025 and 2026, grants a tax credit of 3% of the FOB value for goods and 2% for services, exchangeable for various national taxes.

Costa Rica: The country advances in its fiscal modernization with the implementation of the TRIBU-CR platform. This new system represents a structural change towards digitization and real-time data analysis, integrating billing, declarations and other tax information. The reform requires greater rigor on the part of companies, with VAT declarations and third-party operations declarations that will now be monthly.

Guatemala: The Superintendence of Tax Administration (SAT) has intensified its inspection of transfer pricing. The new approach is based on the use of big data and technology, through tools such as Online Electronic Invoicing (FEL) and integrated audits. The SAT is paying special attention to transactions between local related parties, seeking to detect schemes that erode the country's tax base.

Paraguay: To strengthen its business climate, Law No. 7,548/2025 has been enacted, which establishes a new and more competitive regime of tax incentives for investment. The law offers exemptions from customs taxes, VAT, Non-Resident Income Tax (INR) and Tax on Dividends and Profits (IDU) for projects that meet certain investment amounts, consolidating the country as an attractive destination for national and foreign capital.

Uruguay: A draft Budget Law is under parliamentary discussion that proposes relevant changes effective as of January 2026. The modifications include the tax on real estate capital income obtained abroad, greater tax transparency for foreign companies with Uruguayan residents, and the incorporation of the Global Minimum Tax of 15% for multinationals, in line with OECD guidelines. In addition, the conditions to access the “Tax Holiday” benefit are adjusted.

Together, these reforms reflect a regional trend towards more robust, digitalized tax systems aligned with international standards, presenting both challenges and opportunities for taxpayers in Latin America.

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