Latin American countries tend to have relatively high nominal corporate income tax rates, but they can offer significant tax incentives that can push the effective tax rate down substantially.

For example, headline corporate income tax rates are:

• Argentina – progressive rates ranging from 25 percent to 35 percent.
• Brazil – 34 percent
• Chile 27 percent
• Colombia – 35 percent
• Costa Rica – 30 percent
• Ecuador – 25 percent
• Mexico – 30 percent
• Nicaragua – 30 percent
• Panama – 25-30 percent
• Paraguay – 10 percent
• Peru – 29.5 percent

With the exception of Paraguay, all of the above countries have domestic corporate income tax rates significantly above the 15 percent global minimum rate.

However, free trading zones and tax credits and other incentives can easily reduce the ETR below the 15 percent global minimum rate.

In this article we look at some of the key tax incentive regimes in Latin America and their impact on the Pillar Two GloBE rules and top-up tax calculation.