Executive Summary
Uruguay’s tax authority advanced several landmark initiatives in late 2026, including the operationalization of Pillar Two Domestic Minimum Complementary Tax compensation procedures, approval of a comprehensive 2026-2027 risk-based compliance plan, and activation of the Mercosur-EFTA Free Trade Agreement with Norway and Iceland. Additional updates span individual taxation regimes, VAT administration, customs digitalization, and corporate advance payment mechanics.
Important Updates
Uruguay Operationalizes Pillar Two IMCD Compensation Mechanism via Resolution 2400/026 and Form 5950
The Dirección General Impositiva (DGI) published Resolution No. 2400/026 on October 26, 2026, establishing the conditions for taxpayers to request compensation under the Domestic Minimum Complementary Tax (Impuesto Mínimo Complementario Doméstico – IMCD). This mechanism implements Uruguay’s adoption of the OECD/G20 Inclusive Framework’s Pillar Two Qualified Domestic Minimum Top-up Tax (QDMTT) under Decree 206/026 and Law No. 20,212, establishing a 15% global minimum tax for multinational enterprise groups with annual consolidated revenues exceeding EUR 750 million. The compensation mechanism allows constituent entities located in Uruguay to offset IMCD liabilities against other national taxes or specific tax credits, ensuring the QDMTT qualifies as a covered tax under Global Anti-Base Erosion (GloBE) rules and mitigating double taxation risk.
On November 4, 2026, the DGI released the detailed procedural framework and the official instructive for Form 5950 version 00, the designated mechanism for requesting IMCD compensation. Taxpayers must submit the GloBE Information Return within 15 months of fiscal year-end (18 months for the first year), calculate the Top-up Tax liability per jurisdiction using GloBE rules, and file Form 5950 via the DGI’s electronic portal (‘Mesa de Entrada Virtual’) within 18 months after year-end—for example, by June 30, 2026 for calendar year 2024 groups. Compensation may be applied against Corporate Income Tax (IRAE), IVA technical credits, or other national taxes administered by the DGI, supported by audited consolidated financial statements, jurisdictional GloBE calculations, and proof of tax payments abroad.
The mechanism is critical for cash flow management, as IMCD is paid via advance installments during the year. Erroneous compensation claims may trigger adjustments, interest, fines of up to 200% of the improperly compensated amount, and potential treatment as tax evasion under Article 92 of the Tax Procedural Code. Tax directors and CFOs must integrate IMCD calculations into GloBE compliance workflows and align transfer pricing documentation, Country-by-Country Reporting, and GloBE data pipelines to support compensation requests.
Sources: Article #1 | Article #8 | Article #11
DGI Approves 2026-2027 Tax Compliance Management Plan with Risk-Based Enforcement Focus
The DGI approved its inaugural Tax Compliance Management Plan (Plan de Gestión del Cumplimiento Tributario – PGCT) for the 2026-2027 biennium through Resolution No. 2358/2026, dated October 16, 2026. Mandated by the Organic Law of the DGI (Law 18,834) and aligned with the OECD’s Tax Administration 3.0 framework, the plan establishes a fully risk-based compliance model leveraging advanced analytics, machine learning on CFE electronic invoicing data, and third-party data from banking, customs, and social security systems.
The PGCT is structured around four strategic pillars: (1) strengthening voluntary compliance through simplified digital services and pre-filled returns; (2) risk-based segmentation of taxpayers using data analytics and AI to detect inconsistencies such as VAT gaps and IRAE underreporting; (3) targeted enforcement campaigns focusing on high-risk sectors including construction, e-commerce, professional services, and crypto-assets; and (4) institutional capacity building, including auditor specialization in transfer pricing, the digital economy, and international exchange of information. The plan explicitly creates a ‘Large Taxpayers & MNEs Directorate’ to handle Pillar Two, transfer pricing, and Country-by-Country Reporting.
Effective immediately for the 2026-2027 period, the PGCT sets audit selection criteria without creating new statutory filing obligations. Key milestones include mandatory pre-filled IVA/IRAE returns for 80% of taxpayers in Q1 2027, launch of a ‘Compliance Portal’ with real-time risk scoring in Q2 2027, and full integration of customs and tax data for origin verification by Q4 2027. Taxpayers should conduct internal ‘health checks’ on CFE issuance, transfer pricing documentation, and beneficial ownership registers by December 2026 to mitigate audit triggers.
Sources: Article #3 | Article #15
Mercosur-EFTA Free Trade Agreement Enters Force for Norway and Iceland on November 1, 2026
Uruguay confirmed the entry into force of the Free Trade Agreement between Mercosur and the European Free Trade Association for bilateral relationships with Norway and Iceland, effective November 1, 2026. The agreement was ratified by Uruguay via Law No. 19.876 in October 2020 and implemented through Decree No. 234/021. The partial activation reflects the completion of domestic ratification procedures by Norway and Iceland, while Switzerland and Liechtenstein remain pending. The agreement covers trade in goods, services, investment, government procurement, intellectual property, and sustainable development.
The FTA establishes a progressive tariff elimination schedule with immediate duty-free access for a significant portion of tariff lines and phased reductions of typically 4, 7, or 10 years for sensitive products. Uruguayan exporters gain immediate or accelerated preferences on beef quotas, citrus, rice, wood pulp, and software services, while Uruguay eliminates tariffs on Norwegian and Icelandic fish products, maritime equipment, pharmaceuticals, and high-tech machinery. Rules of Origin follow ‘wholly obtained’ or ‘substantial transformation’ criteria, generally requiring 50% regional value content, with a cumulation clause allowing inputs from other Mercosur or EFTA parties to count as originating.
Importers claiming preferential tariffs must present a Certificate of Origin issued by authorized bodies or an Origin Declaration by approved exporters (invoice declaration up to EUR 6,000 or any value for Authorized Economic Operators). The National Customs Directorate issued Instruction No. 45/2026 detailing HS 2022 correlation tables for tariff phase-out categories (A, B4, B7, B10, E), and exporters must register in the DNA’s ‘Exportador Autorizado’ database to issue self-certifications. Transitional provisions allow goods in transit or storage on November 1, 2026 to benefit if documentation is presented within 12 months, with the first Joint Committee meeting scheduled for Q1 2027.
Sources: Article #6
Secondary Regulatory & Regional Updates
- Impatriate Tax Regime Updates: New taxation options for foreign executives and professionals relocating to Uruguay take effect January 1, 2026, modifying IRPF and IRNR treatment under Law 18.579 and Decree 127/010, with alignment to OECD BEPS Action 5 and EU Code of Conduct standards. Article #2
- Early VAT Intervention Program: The DGI launched a preventive compliance initiative for VAT registrants commencing activities on or after January 1, 2025, using e-invoicing (CFE) analytics to detect declaration inconsistencies and offering a voluntary correction window before formal audits. Article #4
- Online Import Exoneration via VUCE: Private non-profit institutions can now process import tax exoneration requests entirely online through the VUCE platform effective October 29, 2026, reducing processing time to 48-72 hours and integrating with the LUCIA customs system. Article #5
- Mercosur-EU Interim Trade Agreement Six-Month Review: Preliminary data shows a 12% year-on-year increase in Uruguayan exports to the EU, with 85% utilization of the high-quality beef quota and operational approval of the Origin Declaration system replacing EUR.1 certificates. Article #7
- Total VAT Reduction for Non-Residents: Non-resident individuals paying with foreign-issued cards receive a 100% IVA reduction on eligible tourism-related services at point of sale, requiring merchant verification of non-resident status and foreign card origin. Article #9
- IMESI Border Zone Gasoline Reduction: The Specific Internal Tax reduction on premium and super gasoline sales in designated border zones continues to mitigate cross-border price asymmetries, with monthly sworn statements due by the 20th of the following month. Article #10
- Investment Fund Registration Guide: The DGI updated registration requirements for investment funds prior to commencing economic activity, mandating RUT enrollment, beneficial owner disclosure, and digital submission via the ‘Trámites en Línea’ portal under Article 7 of Title 4 TO 1996. Article #12
- IRNR Option Expiration Transition: Individuals whose Non-Resident Income Tax option period expires must automatically transition to Personal Income Tax (IRPF) on worldwide income at progressive rates up to 36%, with the first Form 2100 return due by June 30 of the following year. Article #13
- Form 0307 IRNR/IRPF Option Instructions: Tax residents can formally exercise the IRNR option on foreign-source income using Form 0307 version 00, with filing required within 90 days of acquiring tax residence or by March 31 of the following year. Article #14
- 2026 IRAE Advance Payment Schedule: The DGI published the monthly advance payment calculation worksheet for Corporate Income Tax incorporating updated UI values and a new IMCD coordination line, with monthly payments due on the 20th of the following month. Article #16
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.