An advisory firm of Uruguay recently issued a report concerning the transfer of public companies to a foreign country (and vice-versa). Generally those companies are no longer subject to Uruguay’s corporate income tax (since the company is no longer a resident of Uruguay) and legal representation and the corporate name may be retained. Also, those companies do not need to go through a liquidation process in Uruguay or conform to demerger rules.
However, the company could be subject to Uruguay’s tax on non-residents if it does business in Uruguay and earns income that amounts to a permanent establishment (PE). The company will then be taxed under the rules applicable to PEs.
