Venezuela

Corporate - Branch income

Last reviewed - 04 August 2021

Branches of foreign corporations are subject to the same tax rules as Venezuelan corporations. Inter-branch income and deductions must be eliminated. The positive difference between a branch's annual book and taxable income is deemed to be remitted to the branch's head office (branch profits tax). Such remittances are subject to the 34% flat dividend tax (see Dividend tax in the Income determination section for more information) regardless of whether there is an actual payment unless the branch can provide proof of reinvestment of its profits for a five-year period. If such proof is established, no deemed remittance is assumed.

A Venezuelan taxpayer has to recognise, annually on an accrual basis, income generated in a company or other legal entity it controls that is located in a jurisdiction with low fiscal taxation (JLFT). Further, investments in a JLFT must be declared to the SENIAT.