Published on February 8, 2023
IRS issued a Ruling establishing criteria in the application of CTP COVID- 19 when applying RIVUT considering the Equity as of December 31, 2020.
This will have a substantial impact for taxpayers when complying with their obligations in relation to CTP COVID-19 in March 2022 and 2023.
The IRS has issued Ruling No. NAC-DGECCGC23-00000001 in February 8, 2023 establishing its criteria when determining the Temporary Contribution COVID-19 (CTP COVID-19) for those taxpayers that have applied for the Voluntary, Unique and Temporary Tax Regime for the Regularization of Assets Abroad (RIVUT) until December 31, 2022. The following are the main points of the Ruling:
• The amounts declared in the RIVUT must be considered for the application of the CTP COVID-19 since for both cases the same taxable period is taken for the determination of the taxable base, i.e. December 31, 2020 or January 1, 2021. For the application of the CTP COVID-19, it is reminded that the minimum amounts of equity must be equal or greater than US$1 million, US$2 million and US$5 million for individuals, spouses and companies, respectively.
• In case the CTP COVID-19 has already been declared and paid without considering the effects of the RIVUT, the amended tax return of the CTP COVID- 19 must be filed.
• Interest, fines and surcharges will be applied in the event of late filing and payment of contributions.
