A Strategium interpretation is a technical analysis of a specific structure or transaction: how we read the legal framework article by article, what requirements and evidence each figure demands, and where we see the risk — labeled without euphemisms. It is our professional reading of the topic, not an instruction: we share it with our clients as one more input, so they can make their own decisions with better information.
Analysis of the art. 94 LISR regime: which payments genuinely qualify to be assimilated, the withholding mechanics and their limits, the boundaries where the scheme stops being defensible, and the evidence that must support each payment to withstand review.
Related open reading: Salary-assimilated income: what you gain, what you lose
Request access →The full tax treatment of a loan: formal requirements (contract, certain date), interest and withholdings, the presumptions the SAT triggers against loans that are never repaid, and the file that supports the transaction as genuine financing.
Related open reading: Loan after loan that is never repaid: how the SAT reads it
Request access →Analysis of the most efficient combination for individuals: RESICO (simplified regime) with VAT-exempt or 0%-rate activities. Requirements to remain in the regime, income limits, grounds for expulsion, and the formal obligations that keep the scheme standing.
Related open reading: The RESICO + non-VAT activity formula explained
Request access →The income-tax exemptions on gifts and inheritances (art. 93 LISR) applied with rigor: requirements by type of relative, the reporting obligation that turns exempt income into taxable income when omitted, notarial formalization, and effects on the recipient.
Related open reading: Loans and gifts between family members: the rules
Request access →The tax regime of unions as non-profit legal entities (Title III LISR): what income they may receive, their formal obligations, and the limits that separate legitimate union operation from the schemes the authority pursues.
Related open reading: Payroll and its four authorities: how to shield it
Request access →Effects on the Capital Contribution Account (CUCA) when capital is integrated with intangible assets or through payment-in-kind: valuation and its support, corporate registration, and the consequences on capital reductions and future partner exits.
Related open reading: Contributing your brand to the company: the full strategy
Request access →The tax nature of the subscription premium: its effect on CUCA and on stockholders' equity, the cases in which it constitutes taxable income, and the corporate documentation that supports its treatment in capital increases with new partners.
Related open reading: Selling or transferring shares: CUCA/CUFIN and the tax cost
Request access →The structure and tax effects of a trust set up to secure the education of children or grandchildren: contributions and their treatment, returns, distributions to the beneficiary, and coordination with the rest of the family's wealth architecture.
Related open reading: The trust as a machine for preserving wealth
Request access →One: you request the interpretation you're interested in via WhatsApp — each card's button already carries the document's name. Two: we have a short conversation to understand your case and confirm the interpretation applies to your situation (if it doesn't, we'll tell you — a correct reading for the wrong transaction is expensive). Three: you receive it read-only by email, and if your case warrants adaptation, we quote a tailored interpretation for you.
The library grows as we study new topics. If the one you're looking for isn't here, ask us — it's likely already in progress, or your case may warrant opening it. And a note of intellectual honesty: the interpretation documents how we read the topic, with its legal basis and its nuances; it doesn't replace the judgment of whoever reads it. Our job is to let you decide with the full map — you choose the route.
The existing interpretations cover our clients' most frequent scenarios. When your structure has particularities — and the important ones always do — the analysis is built on your case: same standards, your facts. Write to us and we'll size it up together.