Tratados de doble tributación en Nicaragua y sus efectos en las operaciones económicas y financieras de los contribuyentes transnacionales en el país

Abstract

This research article was carried out with the objective of analyzing the legal and economic effects generated by the lack of double taxation treaties in Nicaragua, and its implications in the economic, commercial and financial operations of transnational taxpayers who carry out transactions in national territory., or with its related parties taxpayers in the country. The scope and effects of double taxation treaties in tax and economic matters are determined, analyzing their concept, structure, legal treatment, and international standards. The income tax regime in international transactions is exposed, according to the Nicaraguan legal system, and the adverse effects that its direct application generates, to the taxpayers in their economic and financial results, in comparison with the effective application of double treaties. taxation, which reduce the burden of local taxes based on Nicaraguan tax regulations, which results in an adverse effect on the country's economy, by not encouraging the attraction of foreign direct investment, particularly from cross-border companies or groups that pay taxes under world income, and who seek corporate financial and tax efficiency, which reduces Nicaragua's competitiveness, as an ideal country for receiving foreign investment.