As from 1 January 2023, passive foreign-sourced income which currently is excluded from the scope of Corporate Income Tax (i.e., real estate rents, dividends, interests, royalties, and other passive income including capital gains), would become taxable income.
Such legal amendment was approved by Uruguayan Parliament on November 16, 2022, echoing certain objections raised by the European Union against so-called “principle of the source” (in force in Uruguay) commented in previous editions of this Newsletter.
However, taxation on such corporate income could be prevented to the extent that the Uruguayan company complies with certain substance requirements in Uruguay.
For further information, please refer to the corresponding notes included in our Tax and Accounting Report (in Spanish):
The above communication has been prepared just for information purposes. It cannot be construed as legal advice provided by Bergstein Abogados.
Should you have any further questions, please feel free to contact Domingo Pereira (dpereira@bergsteinlaw.com) and/or Guzmán Ramírez (gramirez@bergsteinlaw.com)
