The tax administration of Uruguay issued guidance on 29 October 2013 about the applicability of Uruguay’s non-resident income tax and value added tax (VAT) on payments of certain fees paid to foreign companies. According to the guidance foreign companies without activities subject to the non-resident income tax are not subject to VAT.
In the guidance it is also clarified that payments received by these foreign companies as fees or penalties are considered to be Uruguayan-sourced income and therefore are subject to the Non-Resident Income Tax (IRNR).