Date de publication : 06-10-1907
The following information are for the sole purpose of providing a general overview of the local taxation of the Corporate tax aspects of the country. In any case, the information provided below cannot be considered as comprehensive or deemed to constitute specific legal advice.
Yes we tax in Uruguay
New tax reform:
- Presumptive dividend reform entered into force as from 1 March 2017, therefore the first determination of presumptive dividends on profits applies to those taxpayers whose fiscal year ended on 31 December 2019.
New tax treaties: No specific information
Local tax advisors
No specific information on the local tax advisors.
Website Tax administration: Click here
The definition of Permanent Establishment follows the wording of the UN Model:
A place of management, a branch, an office, a factory, a workshop, a place of extraction of natural resources.
Resident companies and non-resident companies are only taxed on their revenues derived from Uruguay sources (« source principle »).
Entities are considered to be resident for tax purposes in Uruguay if they are incorporated in Uruguay.
Note: the definitions of permanent establishment and place of residence are subject to the relevant provisions of any applicable double tax treaty, if any.
Corporate Income Tax
The general CIT tax rate is 25%.
Non-taxable income includes the following:
- Dividends received from qualifying participations
- Certain capital gains deriving from qualifying participations
Non-deductible expenses includes the following:
- Dividends benefiting from the participation exemption
Carry forward : Yes 5 years, but some restrictions may apply.
Carry back: No
Companies should submit the tax return annually within 4 months of the end of the tax period.
Annual tax returns are established by the company on a self-assessment system.
Companies shall pay monthly advance payments.
Whithholding Taxes (payment to foreign companies)
The local tax rates in Uruguay are the following, subject to the provisions of an applicable double tax treaty, if any.
There is a 7% WHT on the profits paid from a branch to its foreign head office.
The general rate of WHT on dividends is 7% of the gross amount.
Note: under the presumptive dividend regime (entered into force as from 1 March 2017), the net taxable income generated more than four fiscal years ago is considered as presumptive dividends on profits in the third month of the following tax year, and as a consequence such income is subject to taxes on dividend in Uruguay.
The general rate of WHT on interest is 12%
Note: there is a 7% WHT for certain interest derived from deposits, bonds,…
The general rate of WHT on Royalties is 12%.
The general rate of WHT on management fees is 12%.
The general rate of WHT on technical services is 12%.
Generally, capital gains are taxed under the regular CIT as general income.
Note: capital gains deriving from qualifying participations are exempt under the participation exemption.
Standard VAT tax rate is 22%
Zero-rated supplies include, subject to certain conditions:
- exports of goods;
Exempt supplies include, subject to certain conditions:
- Certain financial services
- Certain insurance services
Note: exempt transactions differ from zero-rated transactions in that the input VAT associated with exempt transactions is not deductible.
In case where for a tax period, Input VAT exceeds Output VAT, certain non-resident companies (which are not required to register and incur Uruguay-VAT in the course of their business activities in Uruguay) may apply for a refund under the same conditions than resident companies.
No other specific information of VAT in Uruguay.
The general statute of limitation is 5 years starting at the end of the year in which the tax return had to be filed.
The statute of limitation could be extended to 10 years for negligent tax fraud and for wilful tax fraud.
There is no foreign exchange control in Uruguay. Income and capital could be freely repatriated.
There are no thin capitalization rules in Uruguay.
Do not hesitate to share your experience in Uruguay with us in the comments below. Any comments are welcome !