Countries › Uruguay › Guide › 6. Taxes › Digital services taxation in Uruguay: IRNR and IVA on streaming, online services and platforms used from Uruguay, location rules and withholding
Digital services taxation in Uruguay: IRNR and IVA on streaming, online services and platforms used from Uruguay, location rules and withholding
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Last verified: 2026-10-27 · Status: Stable
Since 1 January 2018, income of non residents that provide audiovisual content and other services directly through the internet, platforms or apps to customers in Uruguay is fully Uruguayan source, taxed under IRNR at 12 percent of gross income (25 percent for low tax jurisdictions). Platform intermediation is Uruguayan source for 100 percent of the fee when both supplier and customer are in Uruguay and 50 percent when one of them is abroad; the same location rules drive IVA at 22 percent. The customer is located by IP address or billing address, or by the use of payment means managed from Uruguay; Uruguayan IRAE taxpayers that pay for direct digital services withhold IRNR, while withholding on intermediation fees is suspended.
USD figures use UYU 40.214 per US dollar, the BCU quotation for DLS. USA BILLETE on 26 October 2026; UI amounts use UYU 6.6780 per Unidad Indexada, the BCU quotation for 26 October 2026. Both were retrieved from the BCU quotations service on the verification date; conversions are for orientation only.
Key facts
| IRNR on digital services income of non residents (25 percent low tax) | 12 %T.O. 2023 Title 8 art. 17 and art. 18, as of 2026-10-27 · in force |
|---|---|
| Uruguayan source share of cross border platform intermediation income | 50 %T.O. 2023 Title 8 art. 17 numeral 6), as of 2026-10-27 · in force |
| IVA on digital services from abroad consumed in Uruguay | Taxed at 22 percent as supplied in Uruguay T.O. 2023 Title 10 art. 5, as of 2026-10-27 · in force |
| Digital services rules effective | 1 January 2018 (withholding from 1 July 2018) Decreto Nº 144/018 art. 6; Decreto Nº 149/007 art. 26, as of 2026-10-27 · in force |
| UYU per US dollar used for conversions (BCU, DLS. USA BILLETE, 26 October 2026) | 40.214 UYUBCU quotations service, as of 2026-10-27 · in force |
The rule
1. Income of foreign producers, distributors and intermediaries of films, tapes and direct transmissions, and of non residents that directly render services through the internet, technology platforms, apps or similar means, is fully Uruguayan source from 1 January 2018 when the customer is in Uruguay. Payment through electronic means managed from Uruguay (cards, bank accounts, electronic money) creates a rebuttable presumption that the customer is in Uruguay.
Cost to do it: IRNR at 12 percent of gross Uruguayan source income, which is the taxable base for business income of non residents (Title 8 art. 13 literal A).
Example: A foreign streaming service billing UYU 402,140,000 a year to subscribers in Uruguay owes IRNR of UYU 48,256,800. / US$1,200,000 of IRNR on US$10,000,000 of Uruguayan subscriptions.Texto Ordenado 2023 (DGI), Title 8 IRNR, Title 8 art. 17 numeral 3) (Ley Nº 19.535 art. 248 and 249), 2017-09-25 official text · verified 2026-10-27
Cost to do it: IRNR at 12 percent of gross Uruguayan source income, which is the taxable base for business income of non residents (Title 8 art. 13 literal A).
Example: A foreign streaming service billing UYU 402,140,000 a year to subscribers in Uruguay owes IRNR of UYU 48,256,800. / US$1,200,000 of IRNR on US$10,000,000 of Uruguayan subscriptions.Texto Ordenado 2023 (DGI), Title 8 IRNR, Title 8 art. 17 numeral 3) (Ley Nº 19.535 art. 248 and 249), 2017-09-25 official text · verified 2026-10-27
2. Intermediation in the supply or demand of services through the internet, platforms or apps is Uruguayan source for 100 percent of the income when supplier and customer of the main operation are in Uruguay, and 50 percent when either is abroad.
Cost to do it: 12 percent IRNR on 100 or 50 percent of the fee.
Example: A ride hailing platform earning UYU 40,214,000 of fees on trips inside Uruguay pays IRNR on all of it, UYU 4,825,680. / On US$1,000,000 of fees for bookings with a foreign host, only US$500,000 is Uruguayan source: US$60,000 of IRNR.Texto Ordenado 2023 (DGI), Title 8 IRNR and Title 4 IRAE, Title 8 art. 17 numeral 6); Title 4 art. 60 literal E), 2017-09-25 official text · verified 2026-10-27
Cost to do it: 12 percent IRNR on 100 or 50 percent of the fee.
Example: A ride hailing platform earning UYU 40,214,000 of fees on trips inside Uruguay pays IRNR on all of it, UYU 4,825,680. / On US$1,000,000 of fees for bookings with a foreign host, only US$500,000 is Uruguayan source: US$60,000 of IRNR.Texto Ordenado 2023 (DGI), Title 8 IRNR and Title 4 IRAE, Title 8 art. 17 numeral 6); Title 4 art. 60 literal E), 2017-09-25 official text · verified 2026-10-27
3. Location of the customer: the customer is in Uruguay when the IP address of the device used to contract, or the billing address, is in Uruguay; for continuous services this is assessed at contracting. If neither applies, payment through electronic means managed from Uruguay creates the presumption. Activities count as partly carried out in Uruguay even without physical presence. Technical and advertising services from abroad follow their own rule.
Cost to do it: Systems to geolocate customers and keep evidence.
Example: A subscriber with a Uruguayan IP at sign up is a Uruguayan customer even if later traveling. / A Uruguayan billing address alone is enough to place the customer in Uruguay.Decreto Nº 149/007 (IRNR regulation) and Decreto Nº 150/007 (IRAE regulation), as amended by Decreto Nº 144/018, Decreto Nº 149/007 art. 21 BIS and art. 21 TER; Decreto Nº 150/007 art. 65 BIS and art. 65 TER, 2018-05-22 official text · verified 2026-10-27
Cost to do it: Systems to geolocate customers and keep evidence.
Example: A subscriber with a Uruguayan IP at sign up is a Uruguayan customer even if later traveling. / A Uruguayan billing address alone is enough to place the customer in Uruguay.Decreto Nº 149/007 (IRNR regulation) and Decreto Nº 150/007 (IRAE regulation), as amended by Decreto Nº 144/018, Decreto Nº 149/007 art. 21 BIS and art. 21 TER; Decreto Nº 150/007 art. 65 BIS and art. 65 TER, 2018-05-22 official text · verified 2026-10-27
4. Withholding: Uruguayan IRAE taxpayers and other designated agents that pay or credit fees for the direct digital services of art. 21 BIS withhold IRNR, an obligation in force from 1 July 2018; withholding is suspended for payments for intermediation services of art. 21 TER.
Cost to do it: 12 percent withheld from B2B payments for direct digital services.
Example: A Uruguayan company paying UYU 4,021,400 for an online video service withholds UYU 482,568. / US$12,000 withheld on US$100,000 of B2B digital service fees.Decreto Nº 149/007, as amended by Decreto Nº 144/018, Art. 26 (paragraphs two and three), 2018-05-22 official text · verified 2026-10-27
Cost to do it: 12 percent withheld from B2B payments for direct digital services.
Example: A Uruguayan company paying UYU 4,021,400 for an online video service withholds UYU 482,568. / US$12,000 withheld on US$100,000 of B2B digital service fees.Decreto Nº 149/007, as amended by Decreto Nº 144/018, Art. 26 (paragraphs two and three), 2018-05-22 official text · verified 2026-10-27
5. IVA: services rendered through the internet, platforms, apps or similar means that are used or consumed in Uruguay are treated as rendered entirely in Uruguay, and non residents who are IRNR taxpayers are IVA contributors for the taxed acts they perform. Platform intermediation is fully Uruguayan when both parties are in Uruguay and 50 percent when one is abroad.
Cost to do it: 22 percent IVA on the consideration.
Example: Subscriptions of UYU 402,140,000 bear UYU 88,470,800 of IVA. / US$2,200,000 of IVA on US$10,000,000 of consumer subscriptions.Texto Ordenado 2023 (DGI), Title 10 IVA; Decreto Nº 220/998, Title 10 art. 5 and art. 6 literal D); Decreto Nº 220/998 art. 26 BIS and art. 26 TER, 2017-09-25 official text · verified 2026-10-27
Cost to do it: 22 percent IVA on the consideration.
Example: Subscriptions of UYU 402,140,000 bear UYU 88,470,800 of IVA. / US$2,200,000 of IVA on US$10,000,000 of consumer subscriptions.Texto Ordenado 2023 (DGI), Title 10 IVA; Decreto Nº 220/998, Title 10 art. 5 and art. 6 literal D); Decreto Nº 220/998 art. 26 BIS and art. 26 TER, 2017-09-25 official text · verified 2026-10-27
| Service | Uruguayan source share | IRNR | IVA |
|---|---|---|---|
| Audiovisual and other direct online services to a customer in Uruguay | 100 percent | 12 percent of gross | 22 percent |
| Platform intermediation, both parties in Uruguay | 100 percent | 12 percent of fee | 22 percent of fee |
| Platform intermediation, one party abroad | 50 percent | 12 percent of half the fee | 22 percent of half the fee |
Uruguayan source share and taxes on digital services of non residents (T.O. 2023 Title 8 art. 17; Title 10 art. 5; Decreto Nº 220/998 art. 26 BIS and TER).
Worked example
- A foreign streaming platform earns US$10,000,000 (UYU 402,140,000) a year from subscribers whose IP or billing address is in Uruguay.
- It owes IRNR of 12 percent of that gross income, US$1,200,000 (Title 8 art. 13 and 17), and IVA of 22 percent, US$2,200,000, charged on the subscription price (Title 10 art. 5).
- When a Uruguayan company buys a corporate licence from the same platform, it withholds the IRNR at 12 percent (Decreto Nº 149/007 art. 26).
Step by step
- Determine whether the service is a direct digital service or intermediation.
- Geolocate customers by IP and billing address and keep the evidence.
- Register with the DGI for IRNR and IVA when selling to Uruguayan consumers.
- For B2B sales to Uruguayan companies, expect IRNR withholding on direct services and agree gross up terms.
- For marketplaces, separate bookings with both parties in Uruguay from cross border ones.
Common traps
- IRNR on non resident business income is computed on gross Uruguayan source income, not on profit (Title 8 art. 13 literal A).
- Payment with a Uruguayan card can place a customer in Uruguay even without IP or billing evidence (Decreto Nº 149/007 art. 21 BIS).
- Cross border marketplaces are taxed on half their fees in Uruguay, not zero (Title 8 art. 17 numeral 6).
- Withholding on intermediation fees is only suspended, so the platform itself remains liable (Decreto Nº 149/007 art. 26).
Sources
- IMPO, Texto Ordenado 2023 Title 8 (IRNR)
- IMPO, Texto Ordenado 2023 Title 10 (IVA)
- IMPO, Decreto Nº 144/018
- IMPO, Decreto Nº 149/007
- IMPO, Decreto Nº 150/007
- IMPO, Decreto Nº 220/998
- Banco Central del Uruguay, quotations service
Related pages
- taxes/vat
- taxes/withholding-on-remittances
- sectors/key-sectors-and-rules
- /country/uruguay/
- /calendar/
- Live dashboard
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