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Uruguay Introduces New Rules for the Taxation of Certain Foreign Passive Income to Meet EU Commitments

19 December 2022

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Approved Changes

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Uruguay

Uruguay has published Law 20.095 in the Official Gazette, which contains measures to comply with commitments made with the European Union in July 2021 to address a potentially harmful preferential tax regime identified by the Forum on Harmful Tax Practices. Due to the potentially harmful regime, Uruguay was added to the EU's non-cooperative jurisdictions grey list (Annex II), with a commitment to make necessary amendments by 31 December 2022. The issue concerns the potential use of companies to obtain passive income from foreign sources that escapes taxation due to Uruguay's territorial tax system. Under this system, resident entities are assessed...