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Reform tracker: what changed in Uruguayan business law in 2026 and what starts in 2027

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

Most of the 2026 changes came from the 2025 to 2029 budget law (Ley Nº 20.446, in force 1 January 2026). It added a 15 percent domestic minimum tax for multinational groups with revenue of EUR 750 million or more, taxed dividends paid out of income not subject to IRAE when the shareholder's country gives a credit for them, and renamed the free zones directorate as the national investment incentive directorate. Over 2026, a new COMAP regulation, a rewrite of the anti money laundering law, new employment subsidies and the EU Mercosur interim trade agreement followed, and on 26 October 2026 a decree regulating the new dividend rule was published. From 1 January 2027 the Rendición de Cuentas law (Ley Nº 20.531) applies, bringing a ten day consumer withdrawal right with an online withdrawal button, stock exchange interoperability and lower deposit insurance contributions.

USD figures use UYU 40.21 per US dollar, the Banco Central del Uruguay quotation for DLS. USA BILLETE on 27 October 2026, retrieved from the BCU quotations service on the verification date. Amounts set in indexed units are converted at the UI of UYU 6.6792 published by the BCU for 27 October 2026; conversions are for orientation only.

Key facts

Domestic minimum top up tax, effective rate floor15 %Ley Nº 20.446 art. 665 (T.O. 2023 Title 21 art. 2), as of 2026-10-27 · in force
Group revenue threshold for the domestic minimum tax750000000 EURLey Nº 20.446 art. 665 (T.O. 2023 Title 21 art. 3), as of 2026-10-27 · in force
Budget law Ley Nº 20.446 in force2026-01-01 dateLey Nº 20.446 art. 3, as of 2026-10-27 · in force
Rendición de Cuentas law Ley Nº 20.531 in force2027-01-01 dateLey Nº 20.531 art. 2, as of 2026-10-27 · in force
Consumer withdrawal period for distance sales from 1 January 202710 calendar daysLey Nº 20.531 art. 108, as of 2026-10-27 · in force
General COMAP regulationDecreto Nº 329/025, in force 1 February 2026 Decreto Nº 329/025 art. 23, as of 2026-10-27 · in force
Single charge on postal imports up to US$80060 %Decreto Nº 50/026 art. 2, as of 2026-10-27 · in force
Maximum hiring subsidy for priority groups80 % of monthly payLey Nº 20.506 art. 13, as of 2026-10-27 · in force

The rule

1. The national budget law for 2025 to 2029 applies from 1 January 2026, except where a provision sets another date.Ley Nº 20.446 (Presupuesto Nacional 2025 to 2029), Art. 3, 2025-12-16 official text · verified 2026-10-27 · changed: Promulgated 16 December 2025, published 8 January 2026, in force 1 January 2026.
2. A new Title 21 of the 2023 consolidated tax text creates the Impuesto Mínimo Complementario Doméstico. It reaches constituent entities located in Uruguay of multinational groups with consolidated annual revenue of EUR 750,000,000 or more in at least two of the four preceding fiscal years, when the group's effective tax rate in Uruguay is below 15 percent.Ley Nº 20.446, Art. 665 (Title 21 of the T.O. 2023, art. 2 and 3), 2025-12-16 official text · verified 2026-10-27 · changed: New tax added from the promulgation of Ley Nº 20.446 (16 December 2025).
3. The IRNR exemption for dividends now excludes dividends paid by Uruguayan companies (sociedades anónimas, other commercial companies, SAS, permanent establishments and the other entities listed in Title 4 art. 12 A numerals 1 to 8) out of income not taxed by IRAE, provided the dividend is taxed in the shareholder's country of residence and that country grants a credit for the Uruguayan tax. The rule does not apply when the shareholder cannot use the credit because it has negative taxable income. Dividends out of IRAE taxed income remain taxed as before, and dividends on shares listed on authorized Uruguayan exchanges stay exempt.Ley Nº 20.446 (replacing T.O. 2023 Title 8 art. 19 C); Decreto Nº 255/026, Ley 20.446 art. 657; Decreto 255/026 art. 1 to 5 (rewording Decreto 149/007 art. 6, 7, 22 B and 34 d), 2025-12-16 official text · verified 2026-10-27 · changed: Ley Nº 20.446 art. 657 rewrote the dividend exemption from 1 January 2026; Decreto Nº 255/026 (signed 1 October 2026, published 26 October 2026) amended the IRNR regulation to implement it.
4. The free zones directorate of the Ministry of Economy and Finance is renamed Dirección Nacional de Incentivo a la Inversión, and every legal reference to the former free zones bodies is read as a reference to it.Ley Nº 20.446, Art. 188, 2025-12-16 official text · verified 2026-10-27 · changed: Renaming effective with Ley Nº 20.446 (1 January 2026).
5. A new general regulation of the COMAP investment promotion regime came into force on 1 February 2026. Projects filed between 1 August 2025 and 31 January 2026 could opt into it keeping their filing date, and until 30 April 2026 companies could still file under the previous decree.Decreto Nº 329/025, Art. 23, 2025-12-23 official text · verified 2026-10-27 · changed: Replaced Decreto Nº 268/020 from 1 February 2026; the transition window for the old regime closed on 30 April 2026.
6. Uruguay approved the Interim Trade Agreement between Mercosur, its member states and the European Union, signed in Asunción on 17 January 2026. Argentina is also a party; for the Argentine side see The Argentine Thread guide.Ley Nº 20.462, Sole article, 2026-02-27 official text · verified 2026-10-27 · changed: Approved by Ley Nº 20.462 of 27 February 2026, published 4 March 2026.
7. A new regime for international postal parcels up to 20 kg lets the holder of an import valued at up to US$800 pay a single 60 percent charge on the invoice or declared value instead of all import taxes, with a minimum of US$20 per shipment; individuals also get an annual duty free franchise of up to US$800.
Example: A US$300 parcel under the single payment option pays US$180 (UYU 7,238 at UYU 40.21). / US$180 on a US$300 parcel.Decreto Nº 50/026, Art. 1 to 3, 2026-03-12 official text · verified 2026-10-27 · changed: New postal import regime, signed 12 March 2026 and published 19 March 2026.
8. The anti money laundering law Ley Nº 19.574 had about thirty articles reworded, including art. 29 on declaring cash carried across the border above US$10,000, and gained a new art. 33 BIS; the cash use restriction of Ley Nº 19.210 art. 35 was regulated again, keeping the ceiling of UI 200,000 or 5 percent of the price up to UI 450,000.Ley Nº 20.469; Decreto Nº 238/026, Ley 20.469 art. 1 (rewording Ley 19.574 art. 29 among others); Decreto 238/026 art. 1, 2026-03-19 official text · verified 2026-10-27 · changed: Ley Nº 20.469 promulgated 19 March 2026 and published 10 April 2026; Decreto Nº 238/026 signed 1 October 2026 and published 8 October 2026.
9. A new employment promotion law sets hiring subsidies for groups facing barriers to work, including up to 80 percent of monthly pay for hiring unemployed persons with disabilities, people released from prison within three years or trans persons, and, for example, up to one third (women) or one quarter (men) of pay for unemployed young people aged 15 to 24 out of work for more than 3 months.Ley Nº 20.506, Art. 1 and 13, 2026-06-26 official text · verified 2026-10-27 · changed: Promulgated 26 June 2026, published 17 July 2026.
10. A special route to permanent residence by roots (arraigo) is opened for foreigners who entered regularly before 1 January 2026 and are refugee applicants willing to withdraw their claim or have had it finally rejected. Applications must be made within 12 months of entry into force, extendable once by up to 12 months. The decree enters into force 90 days after its publication on 26 October 2026.Decreto Nº 239/026, Art. 1, 2 and 11, 2026-10-08 official text · verified 2026-10-27 · changed: Published 26 October 2026; by our count the 90 days end on 24 January 2027.
11. The Rendición de Cuentas law for fiscal year 2025 applies from 1 January 2027, except where a provision sets another date.Ley Nº 20.531, Art. 2, 2026-10-01 official text · verified 2026-10-27 · changed: Promulgated 1 October 2026, published 16 October 2026, in force 1 January 2027.
12. For off premises and distance sales, the consumer's right to rescind will be 10 calendar days from the contract or delivery, and online sellers must show a visible link called Botón de arrepentimiento on first access, which counts as a reliable means of notice.Ley Nº 20.531 (replacing Ley Nº 17.250 art. 16), Art. 108, 2026-10-01 official text · verified 2026-10-27 · changed: Applies from 1 January 2027.
13. The BCU is empowered to set interconnection and interoperability requirements between stock exchanges, with reciprocal and non discriminatory access for authorized participants.Ley Nº 20.531 (adding Ley Nº 18.627 art. 88 BIS), Art. 307, 2026-10-01 official text · verified 2026-10-27 · changed: Applies from 1 January 2027.
14. The minimum contribution of banks to the deposit guarantee fund falls to 0.75 per thousand when the fund exceeds 70 percent of the maximum set by the Executive, to 0.50 per thousand above 80 percent and to 0.25 per thousand above 90 percent.Ley Nº 20.531 (adding a third paragraph to Ley Nº 17.613 art. 47), Art. 309, 2026-10-01 official text · verified 2026-10-27 · changed: Applies from 1 January 2027.
AreaChangeEffective date or statusLegal basis
Tax15 percent domestic minimum tax for groups with EUR 750 million revenueIn force (from 16 Dec 2025)Ley Nº 20.446 art. 665
Tax and FXIRNR on dividends out of income not taxed by IRAE, when the shareholder gets a foreign creditIn force 1 Jan 2026; regulated by Decreto Nº 255/026 (published 26 Oct 2026)Ley Nº 20.446 art. 657
InvestingNew COMAP regulationIn force 1 Feb 2026; old regime closed 30 Apr 2026Decreto Nº 329/025 art. 23
InvestingFree zones directorate renamed Dirección Nacional de Incentivo a la InversiónIn force 1 Jan 2026Ley Nº 20.446 art. 188
TradeEU Mercosur interim trade agreement approvedLaw of 27 Feb 2026Ley Nº 20.462
TradePostal imports: 60 percent single charge, US$20 minimum, US$800 franchiseDecree of 12 Mar 2026Decreto Nº 50/026
ComplianceAnti money laundering law reworded; cash ceiling regulated againLaw of 19 Mar 2026; decree of 1 Oct 2026Ley Nº 20.469; Decreto Nº 238/026
LaborHiring subsidies up to 80 percent for priority groupsLaw of 26 Jun 2026Ley Nº 20.506
ImmigrationPermanent residence by arraigo for refugee applicants90 days after 26 Oct 2026 publicationDecreto Nº 239/026
Consumer10 calendar day withdrawal and online withdrawal button1 Jan 2027Ley Nº 20.531 art. 108
FinanceStock exchange interoperability powers for the BCU1 Jan 2027Ley Nº 20.531 art. 307
FinanceLower deposit guarantee fund contributions as the fund fills1 Jan 2027Ley Nº 20.531 art. 309

Status of the main changes (verified 27 October 2026)

Worked example

  • A foreign parent owns a Uruguayan SAS whose 2026 profit includes exempt or foreign source income not taxed by IRAE. Before 2026 a dividend out of that income was outside IRNR. Under Ley Nº 20.446 art. 657, if the parent's country taxes the dividend and grants a credit for the Uruguayan tax, the dividend is now subject to IRNR in Uruguay; if the parent has a tax loss that year and cannot use the credit, the exception does not apply. Model the dividend with your adviser under Decreto Nº 255/026 before declaring it.

Step by step

  1. 1. Large groups: check whether consolidated revenue reached EUR 750 million in two of the last four years and model the Uruguayan effective tax rate against the 15 percent floor.
  2. 2. Review dividend plans for 2026 profits that include income not taxed by IRAE under the reworded Title 8 art. 19 C and Decreto Nº 255/026.
  3. 3. E commerce sellers: build the online withdrawal button and update terms to 10 calendar days before 1 January 2027.
  4. 4. Banks and market participants: follow BCU rules issued under the new interoperability and deposit fund provisions from 2027.
  5. 5. Check this page and the changelog monthly; dates here are those published in the official texts on the verification date.

Common traps

  • Several 2026 tax changes took effect on 1 January 2026 but their regulation came later (the dividend decree was published on 26 October 2026), so returns and withholdings for 2026 must apply the law from January.
  • Ley Nº 20.531 was promulgated in October 2026 but most of it applies only from 1 January 2027; do not apply its consumer or banking changes early unless an article says so.
  • The arraigo decree is not yet in force on the verification date; it starts 90 days after publication.

Sources

Related pages

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