On August 31, 2025 Uruguay’s Executive Branch submitted to Congress a comprehensive bill of legislation which, among others, includes relevant tax changes. Some of them are summarized below:
Qualified Domestic Minimum Top-Up Tax. Along the lines of OECD Pillar Two, such tax would be assessed over multinational groups (revenue exceeding €750m) which in UY are subject to an effective tax rate of less than 15%.
Foreign capital gains. Individual tax residents in UY would be taxed on several foreign-sourced capital gains untaxed as of today, especially those stemming from assets purchase and sale and from real estate rents.
Tax holiday. Individuals acquiring the UY tax residency as from January 1, 2026 would qualify for a full exemption on foreign capital gains for 10 years, followed by a preferential 50% tax rate for five years (as long as a supplementary investment is made).
Indirect transfer. Gains stemming from the transfer of shares in nonresident entities, would be taxed as long as any of the following thresholds has been met over the last 365 days (i) more than 50% of their assets are in Uruguay, or (ii) Uruguayan assets exceed the equivalent of approx. USD 5 millions.
Dividends. Dividends distribution untaxed as of this date, would be taxed (7%) where the foreign jurisdiction taxes the dividends and recognizes a tax credit for the tax withheld in UY.
If approved, the bill is scheduled to become effective as of January 1, 2026. Some political analysts anticipate that, in all likelihood, the bill would be subject to diverse changes in the course of the legislative process.
