Uruguay has issued a decree establishing DMTT rules for large multinational groups, covering tax calculations, transitional and permanent safe harbours, filing deadlines and payment requirements. 

RF Report

Uruguay’s government’s Executive Branch issued a decree on 16 October 2026, yet to be published in the Official Gazette, establishing the domestic minimum top-up tax (DMTT) (Impuesto Mínimo Complementario Doméstico or IMCD) regulations, introduced under the National Budget Law for 2025–2029.

Uruguay’s DMTT regulations establish rules for large multinational enterprise groups, covering taxpayer scope, tax calculations and exemptions. They also address adjusted covered taxes, corporate reorganisations, fiscal neutrality and transitional safe harbours in line with global anti-base erosion standards.

Scope & taxpayer thresholds

Uruguay’s IMCD applies to local entities within multinational enterprise groups with consolidated annual revenues of at least EUR 750 million in two of the four preceding fiscal years. The rules also cover joint ventures and their subsidiaries in Uruguay, with specific exclusions for qualifying sovereign wealth funds, investment funds and real estate investment vehicles.

Computation of tax base & accounting rules

Uruguay’s DMTT regulations calculate eligible profit or loss using the net accounting result before intragroup consolidation eliminations, with adjustments for permanent accounting differences exceeding EUR 1 million. They also provide annual and five-year elections covering debt forgiveness, dividends, foreign exchange hedging, equity investments, pension items and transfer pricing. An administrative carry-forward mechanism applies to excess negative tax expenses in specified circumstances.

Safe harbours

Transitional CbCR safe harbour

During the transition period—defined as fiscal years starting on or before 31 December 2027 (excluding fiscal years ending after 30 June 2029)—the DMTT  is treated as zero if the MNE group satisfies at least one of three tests based on qualified Country-by-Country (CbC) report data:

  • De minimis test: Total revenue < EUR 10 million and profit before tax < EUR 1 million in Uruguay.
  • Simplified ETR test: Simplified Effective Tax Rate equal to or higher than the statutory transition rate—16% for fiscal years beginning in 2025, and 17% for fiscal years beginning in 2026 and 2027.
  • Routine profits test: Profit before tax is equal to or lower than the Substance-Based Income Exclusion (SBIE) calculated for Uruguay.
  • Hybrid arbitrage restrictions: Safe harbour calculations must exclude memory-distorting effects from hybrid arbitrage arrangements (deduction/non-inclusion, duplicate losses, or duplicate tax recognition) entered into after 15 December 2022.

Permanent safe harbours

Permanent relief is available through simplified calculations under the routine profits test, de minimis test (average revenue below EUR 10 million and average profit below EUR 1 million), and effective tax rate test (15%). These simplified rules also apply to non-material constituent entities that are not consolidated line by line solely because of their size or materiality.

Administrative provisions: Filing, currency & DGI role

  • Filing and payment deadline: The designated local reporting entity must submit the local tax declaration (aligned with the GloBE Information Return / GIR format) and settle the tax on behalf of all local constituent entities no later than 15 months after the end of the reporting fiscal year.
  • Transitional extension: The Tax Authority (DGI) may extend the filing deadline up to 18 months for the group’s first transition fiscal year.
  • Assessment vs. payment currency: Uruguay’s DMTT is calculated in the presentation currency used in the ultimate parent entity’s consolidated financial statements but must be paid in Uruguayan pesos (UYU). Conversion uses the Central Bank of Uruguay’s interbank buying rate from the day before payment or the statutory due date, whichever comes first. Euro-denominated thresholds are converted using December average exchange rates set by the European Central Bank or the Central Bank of Uruguay.
  • Tax authority administration: Uruguay’s DGI will administer the DMTT under OECD guidance and GIR standards. Local entities may be exempt from filing if the GIR is submitted by the ultimate parent or a designated entity in a jurisdiction with an active agreement with Uruguay.