Income is generated in cash, goods, services, or credit by foreign entities, and income presumptively determined by the tax authorities, even if such income has not been distributed by such entities to taxpayers.

Passive income is considered to be: interest; dividends; royalties; gains from the sale of shares, securities, or intangible assets; gains from derivative financial transactions when the underlying asset relates to debt or shares; commissions and fees, as well as income from the sale of assets not physically located in the country or jurisdiction where the entity resides or is located; and income from services provided outside of said country or jurisdiction, or to persons not residing in said country or jurisdiction, as well as income from the sale of real estate, income from granting the temporary use or enjoyment of assets, and income received gratuitously.

There is a special treatment related to income from services provided to persons who do not reside in the country or jurisdiction where the foreign entity resides or is located.