On 10 September 2026, the Uruguayan Directorate General of Taxation (Dirección General Impositiva – DGI) published its monthly Informative Bulletin No. 639 covering the month of August 2026. This bulletin serves as the primary official channel for communicating legislative amendments, administrative resolutions, judicial rulings, and procedural guidance to taxpayers, tax advisors, and multinational enterprises operating in Uruguay. The release continues the DGI’s commitment to transparency and regulatory certainty, providing a consolidated reference for compliance obligations arising from recent tax reforms, including updates to the Income Tax (IRAE), Value Added Tax (IVA), and cross-border taxation regimes. The bulletin also incorporates interpretations of recent Supreme Court decisions affecting permanent establishment determinations and the application of treaty benefits under the OECD Model Convention. Tax professionals should treat this publication as a mandatory reference for quarterly compliance planning and year-end tax provisioning.
Key Takeaways
- Updated VAT Compliance Requirements for Digital Services: The bulletin outlines new reporting obligations for non-resident digital service providers under the expanded VAT collection regime effective since January 2026. It clarifies the threshold for mandatory registration, invoicing standards in electronic format, and the timeline for quarterly tax remittances. Taxpayers must ensure their e-invoicing systems align with the DGI’s technical specifications by 31 October 2026 to avoid penalties. The guidance also addresses the treatment of digital platform operators as withholding agents and the required data fields for transaction-level reporting to the tax administration’s centralized platform.
- Income Tax (IRAE) Deduction Limitations and Transfer Pricing Documentation: Recent amendments to the IRAE law introduce stricter limitations on the deductibility of interest expenses exceeding a 3:1 debt-to-equity ratio for related-party loans. The bulletin provides interpretative guidance on the application of the arm’s length principle, mandatory transfer pricing documentation thresholds, and the new country-by-country reporting (CbCR) obligations for multinational groups with consolidated revenues exceeding EUR 750 million. It further specifies the format and deadline for the annual transfer pricing affidavit, now due within nine months of the fiscal year-end, and introduces a safe harbor regime for routine low-value intra-group services.
- Enhanced Dispute Resolution and Advance Pricing Agreement (APA) Procedures: The DGI has updated its procedural rules for mutual agreement procedures (MAP) under double tax treaties and unilateral advance pricing agreements. The bulletin details the revised submission timelines, required documentation, and the introduction of a fast-track process for low-risk transactions. Taxpayers with pending cross-border disputes are encouraged to review the new framework to optimize resolution strategies. Notably, the DGI has committed to issuing a formal opinion within 12 months for complete APA applications meeting the new checklist requirements, reducing previous uncertainty in bilateral negotiations.
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.
Source: Read Official Announcement