On 14 September 2026, the Ministry of Economy and Finance released a formal response to a parliamentary request for information submitted by Representative Gustavo Salle Lorier. The inquiry, grounded in Article 118 of the Constitution and Law No. 17.673 on legislative oversight, sought detailed clarification on the current status, implementation, and effects of Decree No. 163/020 and Article 648 of Law No. 20.446. Decree 163/020, enacted in March 2020, introduced a series of emergency tax measures to mitigate the economic impact of the COVID-19 pandemic, including payment deferrals for income tax (IRAE), value-added tax (IVA) credits for affected sectors, and temporary reductions in social security contributions for employers who maintained payroll. Article 648 of Law 20.446, the Budget Law for the 2025-2029 period, contains provisions on tax administration, compliance incentives, and the regularization of outstanding obligations, including a voluntary disclosure regime for undisclosed assets. The government’s response outlines the regulatory hierarchy between the emergency decree and the permanent budget law, details any extensions or modifications made to the original measures, and provides statistical data on taxpayer uptake and fiscal impact. Specifically, the response indicates that as of 30 June 2026, approximately 42,000 taxpayers had benefited from the payment deferral provisions of Decree 163/020, with a total deferred tax liability of UYU 12.4 billion. Meanwhile, the voluntary disclosure regime under Article 648 has attracted 3,800 participants, yielding UYU 4.7 billion in previously undeclared tax revenue. This exchange underscores the legislature’s active role in scrutinizing tax policy, particularly the transition from crisis-driven relief to structural fiscal rules. The response also addresses questions regarding the legal certainty of provisions that originated as temporary measures but have been incorporated into the ordinary tax framework.
The parliamentary inquiry reflects broader political debates about the fairness and efficiency of pandemic-era tax relief. Representative Salle Lorier, a member of the opposition, has repeatedly questioned whether the benefits were adequately targeted and whether the fiscal cost was justified. The Ministry’s response includes a sectoral breakdown showing that the tourism, hospitality, and retail sectors accounted for 68% of the deferral beneficiaries. Additionally, the response clarifies that the emergency measures expired on 31 December 2022, and any remaining balances were incorporated into standard payment plans under the general tax code. The interaction between Decree 163/020 and Article 648 is particularly relevant for taxpayers who utilized both regimes: the response confirms that participation in the voluntary disclosure regime does not preclude prior use of emergency deferrals, but it does require full payment of any outstanding deferred amounts before the disclosure benefits apply. Tax advisors should note that the Ministry has committed to publishing a comprehensive evaluation report by 31 December 2026, which may inform future legislative adjustments.
Key Takeaways
- Legislative Scrutiny of Pandemic Tax Relief: The parliamentary inquiry signals ongoing political and fiscal evaluation of emergency measures, with potential implications for their continuation, modification, or termination.
- Clarification of Regulatory Hierarchy: The response delineates how Decree 163/020 interacts with Law 20.446, providing taxpayers and advisors with a clearer understanding of which provisions remain in force and under what legal authority.
- Potential for Legislative Amendment: The inquiry may catalyze formal legislative proposals to amend, consolidate, or sunset specific tax provisions, affecting compliance planning for businesses operating in Uruguay.
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