The new decree clarifies how pre-existing fiscal stability clauses apply under the Pillar 2 domestic minimum top-up tax.
Uruguay Uruguay’s Ministry of Economy and Finance issued Decree No. 325/025 on 29 December 2025, detailing how fiscal stability clauses that existed before the introduction of the Pillar 2 Qualified Domestic Minimum Top-Up Tax (QDMTT), or Impuesto Mínimo Complementario Doméstico (IMCD) in Spanish, should be applied.
The decree sets out rules for the Domestic Minimum Complementary Tax, which targets large multinational corporations. Its main goal is to reconcile the new 15% tax rate with existing fiscal stability clauses in laws governing free trade zones and the forestry sector.
The exemption covers either the portion of the QDMTT that exceeds the Pillar 2 global minimum tax applicable abroad or the portion that cannot be credited internationally.
Under certain conditions, eligible companies may receive full or partial exemptions from the tax to honour prior legal commitments and comply with international standards. The decree also provides a process for the General Tax Directorate to issue refunds if a company has already overpaid.
To take advantage of these provisions, businesses must open an administrative file and provide transparency about their global tax position. The measure aims to preserve legal certainty for investors while ensuring Uruguay aligns with international efforts to prevent tax base erosion.
Earlier, Uruguay’s Senate confirmed the effective date for the qualified minimum domestic top-up tax (QMDTT) in the 2025–2029 Budget Bill amendments on 3 December 2025.
