On 4 January 2019, Uruguay’s Directorate General of Taxation (DGI) has issued Resolution No. 94/2019 regarding submission of Country-by-Country (CbC) reports and notifications. Uruguay’s CbC reporting requirements apply fiscal years beginning on 1 January 2017 and onwards.
The Resolution includes large MNE groups which consolidated revenue is equal or more than EUR 750 million must submit CbC reports in Uruguay, except for when the CbC report must be filed by another entity member of the Large MNE Group to the tax administration of a jurisdiction with which Uruguay has an exchange of information agreement in force, and the CbC report can be effectively shared with the DGI.
If DGI verifies that a CbC report cannot be exchanged, despite the existence of necessary agreements for CbC exchange, DGI will notify a local entity for submission. The CbC report must contain required information in accordance with Decree No. 353/2018. It must be submitted in the XML format within 12 months following the end of the reporting fiscal year.
According to the Regulatory Decree, the CbC report must include:
- Information on each entities of a multinational group, the tax residence jurisdiction, the country of incorporation, and the activities carried out;
- Consolidated gross revenue, revenue obtained with related parties and independent firms, profits before taxes, income tax paid and accrued, share capital, retained earnings, number of employees and intangible assets.
Where there are multiple entities of a group in Uruguay, any entity may submit a CbC report on behalf of the others, although if any entity is the ultimate parent entity or designated reporting entity, the report must be submitted by that entity.
With respect to reporting fiscal years ending between 31 December 2017 and 30 November 2018, the CbC report submission deadline is extended to 15 months after the reporting fiscal year. With respect to reporting fiscal years ending between 31 December 2017 and 28 February 2019, the CbC notification submission deadline is extended to 31 March 2019.
