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February 3, 2020

Uruguay’s tax authorities update list of low- or no-taxation countries and jurisdictions and aligns it with the transfer pricing list

In Resolution No. 001/2020 (effective 1 January 2020), Uruguay’s tax authorities align the list of low- or no-taxation (LONT) countries and jurisdictions with the transfer pricing (TP) list so that one list applies for TP and other tax purposes.


Under Decree No. 393/019, countries and jurisdictions will be considered LONT for TP purposes when the following conditions are met:

  • An effective tax rate of less than 12% applies to income from activities performed, goods situated (e.g., real estate), or rights economically carried out (e.g., rights to use a brand) in Uruguay
  • The country or jurisdiction has one of the following with Uruguay:
    • An information exchange agreement that is not in force
    • An income tax treaty with an information exchange clause that is not in force
    • An information exchange that is in force but does not apply to all taxes


  • An income tax treaty with an information exchange clause that is in force but does not apply to all taxes

These conditions align the TP rules with the LONT criteria that applies for other tax purposes.

The decree also required the tax authorities to prepare a list of countries and jurisdictions that would qualify as LONT. The list appears in Resolution 001/2020.

Resolution No. 001/2020

The following 40 countries and jurisdictions are on the list:


French Polynesia

Maldives Island

Saint Martin (Former member of the Netherlands Antilles)

Antigua and Barbuda



Saint Pierre and Miquelon



Norfolk Island

Solomon Islands





Christmas Islands


Pacific Islands


Cocos Island (Keeling Island)


Palau Island


Commonwealth of Dominica


Pitcairn Island

Tristan da Cunha



Puerto Rico


Falkland Island


Kingdom of Tonga

US Virgin Islands

Fiji Island


Saint Helena Island


The Resolution allows countries or jurisdictions on the list to be removed, provided certain conditions are met:

  • The exchange of information on request fully applies.
  • The automatic exchange of information on financial accounts for tax purposes is activated bilaterally by Uruguay’s Ministry of Economy and Finance.

For additional information with respect to this Alert, please contact the following:

Ernst & Young Uruguay, Montevideo
Ernst & Young LLP (United States), Latin American Business Center, New York
Ernst & Young LLP (United Kingdom), Latin American Business Center, London
Ernst & Young Tax Co., Latin America Tax Desk, Japan & Asia Pacific




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