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Foreign investment regime: guarantees, COMAP incentives, free zones and the few limits

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Last verified: 2026-10-27 · Status: Changing

Uruguay admits foreign investment with no prior authorization or registration, gives it the same treatment as local investment and guarantees by law the free transfer abroad of capital and profits. The main incentive is the COMAP promotion regime, which since 1 February 2026 runs under Decreto Nº 329/025: promoted projects exonerate IRAE by a share of eligible investment set by an indicator matrix, and projects above UI 180 million filed by the end of 2027 can exonerate 100 percent. Free zone users are exempt from national taxes except social security and the new domestic minimum tax, and companies that own rural land must have shares held by individuals unless the Executive authorizes otherwise.

USD figures use UYU 40.214 per US dollar, the Banco Central del Uruguay quotation for DLS. USA BILLETE on 26 October 2026, and the Unidad Indexada (UI) at UYU 6.6792 for 27 October 2026, both retrieved from the BCU quotations service on the verification date. Thresholds the law sets in UI are quoted as written; conversions are for orientation only and move with the UI and the exchange rate.

Key facts

Prior authorization or registration needed to invest	None Ley Nº 16.906 art. 3, as of 2026-10-27 · in force
Foreign investors get the same admission and treatment as nationals	Yes Ley Nº 16.906 art. 2, as of 2026-10-27 · in force
Free transfer abroad of capital and profits in freely convertible currency	Guaranteed by law Ley Nº 16.906 art. 5, as of 2026-10-27 · in force
COMAP promoted projects: maximum share of yearly IRAE payable that can be exonerated	90 %Decreto Nº 329/025 art. 16, as of 2026-10-27 · in force
COMAP term to recommend on a promoted project	90 business daysDecreto Nº 329/025 art. 8, as of 2026-10-27 · in force
Minimum period to use the IRAE exoneration	4 fiscal yearsDecreto Nº 329/025 art. 17, as of 2026-10-27 · in force
Standard period in which eligible investment must be executed	5 fiscal yearsDecreto Nº 329/025 art. 4 (Decreto Nº 152/026), as of 2026-10-27 · in force
Minimum unit value of eligible movable goods	1500 UIDecreto Nº 329/025 art. 3, as of 2026-10-27 · in force
Eligible investment above which 100 percent IRAE exoneration is available (filed before 31 Dec 2027)	180000000 UIDecreto Nº 329/025 art. 20, as of 2026-10-27 · in force
Eligible investment above which 100 percent IRAE exoneration is available (filed before 31 Dec 2028)	300000000 UIDecreto Nº 329/025 art. 20, as of 2026-10-27 · in force
Extra IRAE benefit for micro and small companies	15 percentage pointsDecreto Nº 329/025 art. 19, as of 2026-10-27 · in force
Tolerance margin on the committed indicator score	10 %Decreto Nº 329/025 art. 13, as of 2026-10-27 · in force
Maximum holding period for promoted fixed assets (tax useful life, capped at 10 years)	10 yearsDecreto Nº 329/025 art. 12, as of 2026-10-27 · in force
Free zone users: minimum share of Uruguayan staff	75 %Ley Nº 15.921 art. 18 (Ley Nº 20.446 art. 196), as of 2026-10-27 · in force
Free zone service users: minimum share of Uruguayan staff	50 %Ley Nº 15.921 art. 18 (Ley Nº 20.446 art. 196), as of 2026-10-27 · in force
Free zone direct user contract: maximum term for industrial activities	15 yearsLey Nº 15.921 art. 16, as of 2026-10-27 · in force
Free zone direct user contract: maximum term for commercial or service activities	10 yearsLey Nº 15.921 art. 16, as of 2026-10-27 · in force
BCU quotation, DLS. USA BILLETE	40.214 UYU per USDBanco Central del Uruguay quotation, as of 2026-10-26 · in force
Unidad Indexada (UI) value	6.6792 UYUBanco Central del Uruguay quotation, as of 2026-10-27 · in force

The rule

1. Promotion and protection of investments by national and foreign investors is declared of national interest. Foreign investors get the same admission and treatment regime as nationals, investments are admitted without prior authorization or registration, the State commits to fair treatment and not to harm the installation, management, maintenance, use, enjoyment or disposal of investments through unjustified or discriminatory measures, and it guarantees the free transfer abroad of capital, profits and other sums linked to the investment in a freely convertible currency.
Cost to do it: No admission filing, registration or fee exists for a foreign investment: UYU 0 (US$0).
Example: A foreign parent can capitalize UYU 402,140,000 into a Uruguayan company without any investment registration and later repatriate that capital and its profits in dollars. / UYU 402,140,000 is US$10,000,000 at UYU 40.214.Ley Nº 16.906 (Investment and Industrial Promotion Law), Art. 1, art. 2, art. 3, art. 4 and art. 5, 1998-01-07 official text · verified 2026-10-27

2. Companies whose investment projects the Executive declares promoted, on the advice of the Comisión de Aplicación (COMAP), access the tax benefits of Chapter III of the investment law. The COMAP is coordinated by the Ministry of Economy and Finance and includes the ministries of Industry, Livestock and Agriculture, Labor, Environment, the Planning and Budget Office and the Decentralization Commission. Since the 2025 to 2029 budget law, COMAP coordination sits within the new Dirección Nacional de Incentivo a la Inversión of the Ministry of Economy and Finance, which also took over the free zones directorate.
Cost to do it: The law sets no fee to apply for promotion.Ley Nº 16.906 art. 11 and art. 12 (inciso 1 as worded by Ley Nº 20.446 art. 195); Ley Nº 20.446 art. 188, Ley 16.906 art. 11 and 12; Ley 20.446 art. 188 and 195, 2025-12-16 official text · verified 2026-10-27 · changed: Ley Nº 20.446 of 16 December 2025 (published 8 January 2026) renamed the Dirección Nacional de Zonas Francas as Dirección Nacional de Incentivo a la Inversión, placed COMAP coordination under it, and reworded the COMAP composition in art. 12 of Ley 16.906.

3. Under the current general promotion regime, cooperatives and IRAE taxpayers with income taxed by IRAE may apply, provided the investment serves the activities that generate that income; farm producers qualify if they pay IRAE on their farming. State industrial and commercial enterprises and tobacco companies are excluded. Eligible investment is movable fixed assets used directly and essentially in the project with a minimum unit value of UI 1,500 (non utility vehicles and household goods excluded), construction or fixed improvements (including on leased property with at least 3 years left on the lease), certain biological assets such as fruit plantations and breeding cattle and sheep in genetic programs, and other intangibles or biological assets the COMAP determines. Investments under another IRAE exoneration regime, and the part funded by public subsidies, do not count.
Example: The UI 1,500 floor is about UYU 10,019 at UYU 6.6792 per UI: a UYU 8,000 tool does not count as eligible investment. / About US$249 per unit.Decreto Nº 329/025 (update of the general investment promotion regime under Ley 16.906), Art. 1 and art. 3, 2025-12-23 official text · verified 2026-10-27 · changed: Decreto Nº 329/025, in force from 1 February 2026, replaced Decreto Nº 268/020 as the general COMAP regulation; projects could still be filed under Decreto Nº 268/020 until 30 April 2026. Among other changes it raised the minimum value of eligible movable goods from UI 500 per concept acquired to UI 1,500 per unit and added breeding livestock and genetic material as eligible biological assets.

4. Eligible investment is the one executed from the filing date of the application and for up to 5 following fiscal years, plus investment made in the 6 months before the first day of the filing month if needed for the project and not above 20 percent of total eligible investment. Projects above UI 180,000,000 that need longer may ask, when filing, for a schedule of up to 10 fiscal years, and force majeure allows an extension of up to 2 years if requested before the schedule expires. The amount of the project is measured with the UI of the last day of the month before filing and the exchange rate of the last business day of that month.
Example: UI 180,000,000 is about UYU 1,202,256,000. / About US$29.9 million.Decreto Nº 329/025, Art. 3 and art. 4 (art. 4 as worded by Decreto Nº 152/026), 2026-06-26 official text · verified 2026-10-27 · changed: Decreto Nº 152/026 of 26 June 2026 reworded art. 4 of Decreto Nº 329/025 on the computable investment period. Under Decreto Nº 268/020 the window was up to 10 fiscal years for every project.

5. The COMAP scores each project on a matrix of six indicators: employment generation, decentralization, export growth, environmental sustainability, technological adaptation with research, development and innovation, and a strategic indicator. It sets the minimum score for promotion and the benefits follow from the score. The application includes company and owner data, accounting and economic information, a sworn commitment to the investment amount and indicators, and a declaration of related companies. It counts as filed once the COMAP validates it; missing information must be supplied within 10 business days. The COMAP has 90 business days from validation to recommend; the term can be suspended for up to 30 business days for more information, extendable by another 30 at the company's request. If the COMAP does not decide in time it is deemed to recommend granting the benefits; if the company does not answer in time the application is deemed withdrawn.
Cost to do it: No government fee is set in the decree; preparing the project, the indicator projections and the yearly follow up returns usually requires accountants or consultants whose fees are not regulated.Decreto Nº 329/025, Art. 5, art. 6, art. 7, art. 8 and art. 9, 2025-12-23 official text · verified 2026-10-27 · changed: From 1 February 2026 the information suspension was cut from up to 90 business days under Decreto Nº 268/020 to 30 business days plus an optional 30, the five day single window step was replaced by COMAP validation, and the indicators 'clean technologies' and 'sectoral' were replaced by 'environmental sustainability' and 'strategic'.

6. A promoted project exonerates IRAE by a percentage of eligible investment that results from the indicator matrix. In each year of the benefit period the exonerated tax cannot exceed 100 percent of the amount actually invested nor 90 percent of the IRAE payable. The COMAP sets the period of use, never shorter than 4 fiscal years; it runs from the first year with net taxable income if that happens within 4 years of the promotion, otherwise the period is extended by 4 years and runs from the year of the promotion, and the company may suspend it for up to 2 fiscal years. Investment made between the start of the year and the IRAE return deadline can be counted in that year.
Example: Illustration only: a company with UYU 800,000,000 of IRAE taxable income owes UYU 200,000,000 of IRAE at 25 percent; with enough unused exoneration it can exonerate at most UYU 180,000,000 that year and still pays UYU 20,000,000. / About US$19.9 million of taxable income, US$4.97 million of IRAE, at most about US$4.48 million exonerated and about US$0.5 million paid.Decreto Nº 329/025, Art. 16 and art. 17, 2025-12-23 official text · verified 2026-10-27

7. Projects with eligible investment above UI 180,000,000 can exonerate IRAE for 100 percent of eligible investment if filed before 31 December 2027 and fully executed before 31 December 2029. Projects above UI 300,000,000 can do so if filed before 31 December 2028 and fully executed before 31 December 2031. The COMAP sets minimum scores for these benefits, giving priority to the employment and technology and innovation indicators.
Cost to do it: Minimum ticket of more than UI 180,000,000 (about UYU 1,202,256,000 or US$29.9 million) or more than UI 300,000,000 (about UYU 2,003,760,000 or US$49.8 million).
Example: A UI 200,000,000 project (about UYU 1,335,840,000) filed in 2027 and fully executed by 2029 can exonerate up to UYU 1,335,840,000 of IRAE over the period the COMAP sets, never more than 90 percent of any year's IRAE. / About US$33.2 million of investment and the same amount of potential IRAE exoneration.Decreto Nº 329/025, Art. 20, 2025-12-23 official text · verified 2026-10-27 · changed: New incentive for large investment projects introduced by Decreto Nº 329/025, in force from 1 February 2026.

8. Micro and small companies receive 15 additional percentage points of IRAE benefit over the matrix result and 2 more fiscal years to use it; medium companies with up to 50 employees receive 10 additional points and 1 more year. Users of industrial parks and science and technology parks get 15 percent more IRAE benefit and period for industrial, related logistics, solar, waste recovery and technology, biotech or creative services activities, and 5 percent for other activities, plus a credit for employer pension contributions on committed employment inside the park for up to 5 fiscal years for industrial and related logistics users. The final IRAE exoneration can never exceed 100 percent of eligible investment.
Example: Illustration only: a small company investing UYU 10,000,000 whose matrix result is 30 percent gets 45 percent, an IRAE exoneration of up to UYU 4,500,000. / About US$248,670 invested; up to about US$111,901 of IRAE exonerated.Decreto Nº 329/025, Art. 19 and art. 21, 2025-12-23 official text · verified 2026-10-27 · changed: Under Decreto Nº 268/020 micro and small companies got 10 percent more benefit and 1 more year only on projects up to UI 3,500,000 a year; from 1 February 2026 the bonus is 15 points and 2 years with no project size cap, and medium companies with up to 50 employees were added.

9. Promoted projects also exonerate Impuesto al Patrimonio on eligible movable assets for their useful life and on promoted civil works for 8 years in Montevideo or 10 years in the interior; exonerate all import duties and taxes, including VAT, on fixed assets and civil works materials declared not competitive with national industry by the Ministry of Industry; and get a refund of VAT on local purchases of materials and services for the civil works and of movable assets for the project. While the application is pending, the company may pay IRAE and Impuesto al Patrimonio as if the benefits had been granted, and settle any difference without fines or surcharges until the third month after the resolution.
Example: A project buying UYU 50,000,000 (net of tax) of local equipment for the promoted investment recovers the VAT charged on it, UYU 11,000,000 at the 22 percent basic rate. / About US$1,243,348 of equipment and about US$273,537 of VAT refunded.Decreto Nº 329/025, Art. 18 and art. 22, 2025-12-23 official text · verified 2026-10-27

10. Benefits come with follow up and clawback. Within 4 months after each year end, starting with the filing year and even before approval, the company files a sworn return on investment execution, benefits used and indicators, plus its tax return and financial statements with an audit, limited review or compilation report depending on its DGI segment. Promoted fixed assets must be kept for their tax useful life or 10 years if longer. A 10 percent tolerance applies to the committed score; below it, benefits are recalculated to the score achieved and excess exonerated tax is repaid indexed by the UI, and failing to file information or to execute the project can lead to revocation with fines and surcharges. Up to 3 extensions of a promoted project can be filed.
Cost to do it: Yearly audit, limited review or compilation report on the financial statements; professional fees are not regulated.Decreto Nº 329/025 (art. 10 incisos 3 and 4 as worded by Decreto Nº 152/026), Art. 10, art. 11, art. 12, art. 13, art. 14 and art. 15, 2025-12-23 official text · verified 2026-10-27 · changed: The tolerance margin on the committed score fell from 20 percent under Decreto Nº 268/020 to 10 percent, and the threshold below which a partial failure to invest need not be reported fell from 15 percent to 5 percent of eligible investment.

11. Free zone users are exempt from every national tax, existing or future, on the activities they carry out in the zone within the terms of their authorized contract, and goods and services brought into the zone are exempt from import taxes. The exemption does not cover social security contributions nor the Impuesto Mínimo Complementario Doméstico. Users must have as exclusive object the activities allowed by the law and may not carry out industrial, commercial or service activities in the rest of Uruguay except as the law allows. User contracts must be authorized in advance, or they are deemed nonexistent, and last at most 15 years for industrial activities and 10 years for commercial or service activities for direct users and 5 years for indirect users, with no automatic renewal. At least 75 percent of staff must be Uruguayan citizens, or 50 percent for service activities for the term of the user contract; the Executive can reduce these percentages temporarily and must answer requests within 60 days or they are deemed approved.
Cost to do it: Contract fees are agreed with the free zone operator and are not set by law.Ley Nº 15.921 (Free Zones Law), as amended by Ley Nº 19.566 and Ley Nº 20.446, Art. 14, art. 16, art. 18 (as worded by Ley 20.446 art. 196), art. 19, art. 20 (inciso 1 as worded by Ley 20.446 art. 636) and art. 21, 1987-12-17 official text · verified 2026-10-27 · changed: Ley Nº 20.446 of 16 December 2025 excluded the new domestic minimum tax from the free zone exemption (art. 636) and reworded the staffing rule (art. 196): the 50 percent minimum of Uruguayan staff for service users now applies directly for the contract term, where Ley Nº 19.566 allowed it only when the nature of the business required it.

12. It is declared of general interest that rural land and farm operations be owned by individuals, partnerships and other listed entities whose capital is fully represented by registered quotas or shares held entirely by individuals. Sociedades anónimas and partnerships limited by shares may own rural land only if all their shares are registered shares owned by individuals. The Executive may, on request, authorize other companies, branches of nonresident entities, trusts and investment funds when the number of shareholders or the nature of the business prevents ownership by individuals only; the authorization lists the specific properties and must be requested again whenever the holding grows or a property is replaced. Land used for non farming activities is excluded.Ley Nº 18.092, art. 1 as worded by Ley Nº 18.172 art. 349, Art. 1, 2007-01-07 official text · verified 2026-10-27

Item	Decreto Nº 268/020	Decreto Nº 329/025	Source
Minimum value of eligible movable goods	UI 500 per concept acquired	UI 1,500 per unit	Art. 3 of each decree
Computable investment period	Up to 10 fiscal years	5 fiscal years; up to 10 for projects above UI 180 million on request	Art. 4 of each decree (329/025 as worded by Decreto Nº 152/026)
Prior investment counted	6 months before the filing month	6 months before the filing month, capped at 20 percent of eligible investment	Art. 4 of each decree
Suspension of COMAP review for more information	Up to 90 business days	Up to 30 business days, plus 30 at the company's request	Art. 9 (268/020); art. 8 (329/025)
Tolerance on committed score	20 percent	10 percent	Art. 14 (268/020); art. 13 (329/025)
Micro and small company bonus	10 percent more benefit and 1 year, projects up to UI 3.5 million	15 points and 2 years; medium firms up to 50 employees 10 points and 1 year	Art. 20 (268/020); art. 19 (329/025)
Large projects	No specific rule	100 percent of eligible investment above UI 180 million (filed by 2027) or UI 300 million (filed by 2028)	Art. 20 (329/025)
Cap on exonerated IRAE	100 percent of investment and 90 percent of yearly IRAE	Unchanged	Art. 17 (268/020); art. 16 (329/025)

COMAP general regime: what changed from Decreto Nº 268/020 to Decreto Nº 329/025 (sole regime for new filings from 1 May 2026)

Threshold	UI	UYU	Approx. USD
Minimum unit value of eligible movable goods	1,500	10,019	249
Large project, 100 percent IRAE exoneration, filed before 31 Dec 2027	180,000,000	1,202,256,000	29,896,454
Very large project, 100 percent IRAE exoneration, filed before 31 Dec 2028	300,000,000	2,003,760,000	49,827,423

Thresholds in Unidades Indexadas converted at UI = UYU 6.6792 (27 Oct 2026) and UYU 40.214 per US dollar (26 Oct 2026)

Worked example

A foreign group plans a UI 200,000,000 plant (about UYU 1,335,840,000 or US$33.2 million) through a Uruguayan subsidiary. No investment registration is needed (Ley Nº 16.906 art. 3). It files with the COMAP in 2027, scores at least the minimum the COMAP sets for large projects, and executes the whole investment by 31 December 2029 (Decreto Nº 329/025 art. 20). Its potential IRAE exoneration equals 100 percent of eligible investment, UYU 1,335,840,000. In a year with UYU 800,000,000 of taxable income and UYU 200,000,000 of IRAE, it can exonerate at most UYU 180,000,000 and pays UYU 20,000,000 (art. 16); it also recovers VAT on local equipment and civil works purchases and avoids Impuesto al Patrimonio on the promoted movable assets (art. 18). Dividends then leave freely under Ley Nº 16.906 art. 5, subject to the 7 percent IRNR covered in the start page.

Step by step

1. Confirm no sector limit applies: there is no general screening, but rural land ownership by companies requires shares held by individuals or an Executive authorization (Ley Nº 18.092 art. 1), and regulated sectors have their own permits.
2. Choose the incentive route: COMAP promotion under Decreto Nº 329/025 for an IRAE taxpaying company investing in Uruguay, or a free zone user contract under Ley Nº 15.921 for activities carried out inside the zone, accepting its limits on activity in the rest of Uruguay (art. 14). Investments already covered by another regime that exonerates IRAE are not eligible for COMAP (Decreto Nº 329/025 art. 3).
3. File before you invest: only investment executed from the filing date counts, plus up to 20 percent made in the 6 prior months (Decreto Nº 329/025 art. 4).
4. Prepare the application: company and owner data, financials, sworn commitment on investment amount and indicators, related companies (art. 6). Answer any validation request within 10 business days (art. 7).
5. Expect a COMAP recommendation within 90 business days of validation, plus suspensions of up to 30 business days (extendable by 30) for more information; silence counts as a favorable recommendation (art. 8 and 9). Then the Executive issues the promotion resolution.
6. While the resolution is pending, you may pay IRAE and Impuesto al Patrimonio as if the benefits were granted, and settle any difference without fines until the third month after the resolution (art. 22).
7. Within 4 months of each year end file the COMAP sworn return and your financial statements with the required report, and keep promoted assets for their useful life or 10 years (art. 10 and 12).
8. For a free zone, negotiate the user contract with the operator, obtain prior authorization from the Dirección Nacional de Incentivo a la Inversión with a business plan, and file the biennial sworn return on compliance (Ley Nº 15.921 art. 16 and 16 TER; Ley Nº 20.446 art. 188).

Common traps

Decreto Nº 268/020 no longer applies to new filings: from 1 May 2026 only Decreto Nº 329/025 is available, and advice or templates built on the old decree (10 year investment window, 20 percent tolerance, UI 500 floor) are out of date (Decreto Nº 329/025 art. 23).
The 100 percent large project exoneration has hard dates: miss the filing date or leave any part of the investment unexecuted by 31 December 2029 (or 2031) and the condition fails (Decreto Nº 329/025 art. 20).
Investing before filing costs benefits: anything spent more than 6 months before the filing month, or above 20 percent of eligible investment, does not count (Decreto Nº 329/025 art. 4).
Score shortfalls bite: below the 10 percent tolerance benefits are recalculated and excess exonerated IRAE is repaid indexed by the UI; failing to file follow up information can lead to revocation with fines and surcharges (Decreto Nº 329/025 art. 11 and 13).
Indicators cannot be met by shifting results from related companies; if they are offset by contrary results in related companies, exonerated taxes are reassessed with fines and surcharges (Decreto Nº 329/025 art. 11).
Free zone users cannot sell into the rest of Uruguay from the zone through substantive commercial activity, and their tax exemption does not cover social security contributions nor the domestic minimum tax for large groups (Ley Nº 15.921 art. 14 and 20).
A foreign parent company or a branch cannot hold rural farm land directly without an Executive authorization that lists each property (Ley Nº 18.092 art. 1).

Sources

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