Uruguay plans to include the Pillar Two global minimum tax in its upcoming budget, which aims to generate USD 350 million in revenue.
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. This measure is expected to raise around USD 350 million in government revenue, equivalent to between 0.4% and 0.5% of the country’s GDP.
A key part of the OECD/G20 BEPS Project is addressing the tax challenges arising from the digitalisation of the economy. In October 2021, over 135 jurisdictions joined a plan to update key elements of the international tax system that are no longer fit for purpose in a globalised and digitalised economy. The Global Anti-Base Erosion Rules (GloBE) are a key component of this plan and ensure large multinational enterprises pay a minimum level of tax on the income arising in each of the jurisdictions where they operate.
This includes the introduction of the Pillar Two income inclusion rule (IIR) and the undertaxed payment/profit rule (UTPR) to ensure a minimum corporate tax of 15% for large multinational (MNE) groups with annual consolidated revenue of at least EUR 750 million in at least two of the preceding four fiscal years.
The rules apply to all domestic and international groups with a parent company or subsidiary in an EU member state. The bill also proposes implementing a qualified domestic minimum top-up tax (QDMTT) for members of in-scope groups and certain safe harbours.
