07 July 2026 Uruguay issues resolution regulating implementation of new Personal Income Tax regime applicable to foreign-source income - Resolution No. 1517/2026, published in the Official Gazette on 30 June 2026, establishes operational and compliance rules for implementing the new Personal Income Tax regime applicable to income derived from nonresident entities.
- The Resolution clarifies documentary requirements for foreign tax credits, ordering rules for income attribution, withholding obligations in ownership chains, rules for substantiating tax basis and market values, the election to treat withholdings as final tax and the simplified regime, which may remain in force for up to 20 consecutive years.
- The Resolution is effective for implementation of the new regime, with certain withholding obligations and advance payments for the initial period postponed until October 2026.
- Businesses should review ownership structures, withholding agent status, documentation supporting foreign tax credits and tax basis, and processes for advance payments and elections under the simplified or expatriate regimes.
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On 29 June 2026, the Uruguayan Tax Administration (DGI) issued Resolution No. 1517/2026, published in the Official Gazette on 30 June 2026, establishing operational and compliance rules for the implementation of the new Personal Income Tax (PIT) regime applicable to income derived from nonresident entities. The Resolution provides guidance on income attribution, foreign tax credits, withholding obligations, advance payments and transitional measures for the initial implementation period. Area | Main clarifications introduced by Resolution No. 1517/2026 | Foreign tax credits | Establishes documentary requirements to claim foreign tax credits, including taxes paid by nonresident entities subject to the attribution regime and nonresident income tax (NRIT) paid on indirect transfers; excess foreign tax credits may not be carried forward through future withholdings | Attribution regime | Establishes ordering rules for attributing income distributed by nonresident entities and excludes income already effectively taxed under Corporate Income Tax from the attribution regime | Ownership chains | Determines which entity is responsible for withholding obligations in structures involving resident entities, nonresident entities or mixed-ownership chains | Capital gains and investments | Provides rules for substantiating the tax basis of investments, recognizes Bloomberg as the reference source for quoted market values and allows the offset of certain losses against other foreign-source capital income | Withholding agents | Clarifies when resident entities are considered custodians of foreign assets, regulates the election to treat withholdings as final tax and introduces verification requirements for taxpayers benefiting from the expatriate regime | Advance payments | Establishes semiannual advance payments at a 12% rate for foreign-source immovable income, movable income and capital gains where withholding does not apply | Simplified regime | Clarifies that electing the simplified regime (lump sum of approximately US$300k) is accomplished through filing the first tax return and may remain in force for up to 20 consecutive years, during which time the returns should be filed accordingly | Transitional rules | Postpones until October 2026 certain withholding obligations and advance payments corresponding to the initial implementation period |
The Resolution has been published in the Official Gazette on 30 June 2026. Please see the document here (only in Spanish). | * * * * * * * * * * | | Contact Information | For additional information concerning this Alert, please contact: EY Uruguay, Montevideo Ernst & Young LLP (United States), Latin American Business Center, New York | | Published by NTD’s Tax Technical Knowledge Services group; Carolyn Wright, legal editor |
Document ID: 2026-1433 |
