Tax authorities in Uruguay and Peru increase scrutiny on taxpayers

Tax authorities in Uruguay and Peru are implementing stricter oversight and new requirements for taxpayers, leading to legal and procedural concerns.

In Uruguay, the Dirección General Impositiva (DGI) has begun using electronic invoicing data to conduct mass comparisons between taxpayer declarations and third-party reports. While intended to improve system equity, critics argue that the DGI is imposing non-statutory requirements for IRPF (income tax) refunds. When inconsistencies are detected, taxpayers are reportedly being asked to provide physical documentation, such as detailed letters from clients, which may not be legally required by tax regulations.

In Peru, SUNAT is notifying taxpayers of a 5% additional tax rate applied to expenses that lack proper substantiation. This rate is intended to address the “indirect distribution of income to shareholders” through undocumented expenses. However, legal precedents from the Tribunal Fiscal suggest that the additional tax should only apply to disbursements where the final destination of the funds cannot be reliably proven, rather than all reparable expenses.