Through Resolution 2400/026, the DGI has established the conditions under which taxpayers may request the compensation mechanism provided by Decree 206/026 for the Domestic Minimum Complementary Tax (Impuesto Mínimo Complementario Doméstico). This regime implements the OECD Pillar Two Global Anti-Base Erosion (GloBE) rules in Uruguay, ensuring a minimum 15% effective tax rate for large multinational enterprise groups.
Key Takeaways
- Compensation Eligibility Defined: The resolution specifies the criteria and procedural steps for groups to claim credit for taxes paid abroad against the domestic top-up tax liability.
- Alignment with GloBE Rules: The framework mirrors the OECD model rules, providing certainty for multinational groups operating in Uruguay.
- Impact on MNE Groups: Affected entities must evaluate their effective tax rates per jurisdiction and prepare for potential top-up tax obligations starting in fiscal year 2026.
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