The new decree requires ultimate beneficial owners to maintain at least 95% (instead of 5%) of their equity proportions for at least two years to not consider goodwill in corporate restructurings.

In Decree 64/021, Uruguay's Executive Power repealed Decree 21/021(see EY Global Tax Alert, Uruguay modifies when goodwill is not considered in corporate restructurings, dated 11 February 2021), modifying…