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03 September 2026

Uruguay repeals QDMTT exclusion Decree and introduces compensation mechanism for taxpayers under stability clauses

  • On 31 August 2026, the Uruguayan Executive Branch issued a decree, repealing Decree 325/025, and introducing a mechanism to compensate taxpayers covered by stability clauses for an amount equivalent to the Uruguayan Qualifying Domestic Top-up Tax (QDMTT) minus the reduction of foreign taxes due to the payment of the Uruguayan QDMTT.
 

On 31 August 2026, the Uruguayan Executive Branch issued a new decree (the Decree) repealing Decree 325/025 and introducing a new regime to meet commitments with taxpayers covered by stability clauses in line with the procedures established by the Global Anti-Base Erosion (GloBE) rules. (For additional context, see EY Global Tax Alert, Uruguay's Executive Branch sets conditions to exclude Free Trade Zone users, forestry entities and special agreements from QDMTT payment , dated 5 January 2026.)

The Decree introduces information regarding the following:

  • Compliance: Pay-first-then-claim approach, and compliance with formal requirements
  • Stability clauses: Free Trade Zone users, Forestry and Specific government-multinational group agreements, in force before 16 December 2025
  • Compensation: Qualifying Domestic Top-up Tax (QDMTT) paid in Uruguay minus related foreign tax reduction
  • Formal obligations: New formal filing procedure includes: signed petition regarding activation of the stability clause; identification of the multinational group and organizational chart as requested in the GloBE Information Return; country-by-country reporting (CbCR); identification of entities under minimum global tax or foreign taxes against which the Uruguayan QDMTT could be credited; QDMTT assessment; requested compensation assessment with certification of an internationally well-known audit; and a tax secrecy waiver to allow the Uruguayan tax office to communicate and provide documentation to the inclusive framework
  • Evaluation and potential offset: Uruguayan tax office (DGI) reviews filings, can request additional information, terms and conditions to be defined; for request approved before payment expiration date, taxpayer may offset compensation against assessed QDMTT

The Decree has not yet been published in the Official Gazette; it can be accessed here (only in Spanish).

Implications

The Decree establishes a pay-first-then-claim approach with mandatory filings and compliance obligations for taxpayers covered by stability clauses in force before 16 December 2025.

An offset of the compensation may only be used if the DGI approves before the payment expiration date.

* * * * * * * * * *
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: 2026-1898

 
 

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