October 12, 2022
Uruguayan Government submits bill to Parliament to modify Uruguayan CIT source criteria
On 6 October 2022, a bill that would modify the Uruguayan CIT source criteria in order to comply with EU requirements has been submitted to Parliament for discussion.
In July of 2022, a draft bill was published for public discussion detailing the substance requirements that should be met by CIT taxpayers that form part of a multinational group in order to maintain the traditional source criteria with regard to passive income from abroad. See EY Global Tax Alert, Uruguay intends to change its traditional source criteria for corporate income tax purposes to comply with EU requirements, dated 4 August 2022 for further details.
The main conditions were retained in the bill submitted to Parliament. However, the following are the key changes that were included in the revised draft:
The bill now has to get approval from both Chambers and then be enacted by the President and published in the Official Gazette.
Its provisions are expected to enter into force for fiscal years starting from 1 January 2023.
For additional information with respect to this Alert, please contact the following:
EY 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 American Business Center, Japan & Asia Pacific