The Ministry of Finance issued Decree No. 279/016 on 12 September 2016 that contains regulatory provisions for the application of the modifications to tax rules made by Law No. 19,355 of 15 December 2015.
The main provisions of the Decree are summarized below:
-Five percent of the income derived from advertising and propaganda services rendered abroad by CIT taxpayers to other CIT taxpayers would be considered sourced in Uruguay, provided that up to 10% of the user of the services’ total income is subject to CIT.
-The tax valuation criterion of transferable securities and precious metals that are valued at their acquisition cost was modified for fiscal years starting as from 1 January 2016. In this regard, the adjustment of their value can only be determined by the variation of the Consumer Price Index (CPI), instead of the Uruguayan Producer Price Index (UPPI).
-The transfer pricing regulations were modified for fiscal years starting as from 1 January 2016. Specifically, regarding the comparable transactions prices, the comparability differences due to differing dates of occurrence of the transactions should be adjusted according to the variation of the Consumer Price Index, instead of the Uruguayan Producer Price Index.
