Uruguay's Ministry of Economy and Finance initiated, on 28 July, a public consultation on a draft bill that will be submitted to Congress. The draft bill includes measures to comply with certain commitments agreed with the European Union (EU) in 2021. In particular, Uruguay committed to amend its corporate income tax (CIT) rules to address certain aspects identified by the EU Code of Conduct Group as potentially tax harmful.
The draft bill proposes to impose CIT on certain items of passive income received by Uruguayan Entities or Uruguayan PEs of nonresident members of multinational groups (MNGs) from assets exploited outside Uruguay. The draft bill exempts from the proposed taxation taxpayers that comply with certain substance requirements.
The public consultation period ended on 15 August, and the bill should be sent to the Uruguayan Congress in September. Any changes, if approved, are expected to become effective for years beginning as of 1 January 2023.