Uruguay: Economy and Finance Minister proposes amendments to global minimum tax for 2025–29 budget bill 

The 2025–29 Budget Bill proposes a new domestic minimum tax for large multinational groups from 2027.

Uruguay’s Minister of Economy and Finance, Azucena María Arbeleche Perdomo, has introduced proposed changes to the global minimum tax framework (Impuesto Mínimo Complementario Doméstico, IMCD), which form part of the 2025–2029 National Budget Bill.

This tax aligns with the global Pillar 2 GloBE framework and targets multinational enterprise (MNE) groups with global revenues of at least EUR 750 million in two of the last four years. The IMCD would apply if the effective tax rate in Uruguay falls below 15%.

The bill was initially submitted to Congress on 31 August 2025 for debate. However, details of the proposal were later outlined during a presentation by the Ministry of Economy and Finance on 30 September 2025, as recorded in the official meeting minutes.

During the meeting, it was also proposed to expedite the implementation of the IMCD.

The minister proposed amending Article 662 so that the global minimum tax framework (IMCD) would take effect for fiscal years ending on or after the law’s enactment, instead of from 1 January 2026, as initially planned in the Budget Bill. The tax will take effect for fiscal years ending after the law’s enactment, ensuring that income from the 2025 tax year is included.

However, the actual collection of the IMCD is planned to begin in the latter half of 2027.

It also suggests adding a clause authorising the minister to define procedures ensuring the IMCD aligns with existing tax certainty frameworks, such as those governing Free Trade Zones. Under these procedures, companies could formally prove that their Uruguayan operations fall outside the IMCD’s scope, either because their multinational group is not subject to the GloBE Rules or operates in a jurisdiction where Uruguayan taxes cannot be credited.

Earlier, Uruguay’s Undersecretary of the Ministry of Economy and Finance, Martín Vallcorba, announced plans to include the Pillar Two global minimum tax in the upcoming budget bill on 14 June 2025.