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Uruguay's domestic minimum top up tax: 15 percent for multinational groups with 750 million euros of revenue, substance carve outs, de minimis, filing and interaction with incentives

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

Ley Nº 20.446 added Title 21 to the Texto Ordenado 2023, creating the Impuesto Mínimo Complementario Doméstico: Uruguayan entities of multinational groups with consolidated revenue of at least 750 million euros in two of the four prior years pay a top up when the group's effective tax rate in Uruguay is below 15 percent. Excess profit is measured after substance carve outs of 9.6 percent of eligible payroll and 7.6 percent of tangible assets for years beginning in 2025, falling 0.2 points a year to 2028; a de minimis election applies when Uruguayan revenue averages under 10 million euros and profit under 1 million euros. Each in scope entity files a sworn return with the DGI within 15 months of year end (18 months for the first year); the tax is not deductible for IRAE, not a liability for the wealth tax and not covered by the free zone exemption.

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

Domestic minimum top up tax, minimum effective rate15 %Ley Nº 20.446 art. 665, T.O. 2023 Title 21 art. 2, as of 2026-10-27 · in force
Domestic minimum top up tax, group revenue threshold750000000 EURLey Nº 20.446 art. 665, T.O. 2023 Title 21 art. 3, as of 2026-10-27 · in force
Payroll carve out for fiscal years beginning in 20259.6 %T.O. 2023 Title 21 art. 17, as of 2026-10-27 · in force
Tangible asset carve out for fiscal years beginning in 20257.6 %T.O. 2023 Title 21 art. 18, as of 2026-10-27 · in force
De minimis average revenue threshold10000000 EURT.O. 2023 Title 21 art. 23, as of 2026-10-27 · in force
Return deadline after fiscal year end (18 for the first year if extended)15 monthsT.O. 2023 Title 21 art. 71, 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. The tax applies to income of constituent entities of a multinational group when the group's effective tax rate in Uruguay is below 15 percent. Taxpayers are constituent entities located in Uruguay of multinational groups whose ultimate parent's consolidated financial statements show annual revenue of at least 750 million euros in at least two of the four fiscal years immediately before the year examined, prorated for years that are not 12 months. A multinational group is one with at least one entity or permanent establishment outside the ultimate parent's jurisdiction.
Cost to do it: The top up equals the gap to 15 percent on excess profit.
Example: A Uruguayan subsidiary with a 10 percent effective rate and UYU 375,920,472 of excess profit owes about UYU 18,796,024. / About US$467,400 on US$9,348,000 of excess profit at a 5 point gap.Ley Nº 20.446, art. 665 (T.O. 2023 Title 21), Title 21 art. 1, art. 2, art. 3 and art. 4, 2025-12-16 official text · verified 2026-10-27 · changed: New tax added by Ley Nº 20.446 (published 8 January 2026), in force under its art. 3 from 1 January 2026; the carve out schedule refers to fiscal years beginning from 2025.
2. Substance based income exclusion: a payroll carve out equal to 9.6 percent of eligible payroll costs of eligible employees and a tangible asset carve out equal to 7.6 percent of the carrying value of eligible tangible assets, for fiscal years beginning from 2025; both percentages fall by 0.2 points a year for years beginning in 2026 to 2028, with further reductions from 2029.
Cost to do it: Higher payroll and fixed assets in Uruguay reduce the top up base.
Example: For 2026: 9.4 percent of UYU 120,642,000 of payroll plus 7.4 percent of UYU 201,070,000 of tangible assets excludes UYU 26,219,528. / US$3,000,000 of payroll and US$5,000,000 of tangible assets exclude US$652,000 of profit in 2026.Ley Nº 20.446, art. 665 (T.O. 2023 Title 21), Title 21 art. 17 and art. 18, 2025-12-16 official text · verified 2026-10-27
3. De minimis: the local filing entity may elect, year by year, a zero top up for Uruguay when the average qualifying revenue of the Uruguayan entities is below 10 million euros and their average qualifying profit is a loss or below 1 million euros, averaging the current and two prior years. Safe harbours may also deem the top up to be zero under terms set by the Executive Branch.
Cost to do it: Election in the return; no tax if met.
Example: A small Uruguayan sales office of a large group with 6 million euros of revenue and 500,000 euros of profit on average can elect zero. / Below 10 million euros of revenue and 1 million euros of profit on average, the top up can be zero.Ley Nº 20.446, art. 665 (T.O. 2023 Title 21), Title 21 art. 23 and art. 72, 2025-12-16 official text · verified 2026-10-27
4. Each constituent entity located in Uruguay files a sworn return with the DGI with the group's entities, corporate structure and the data to compute effective rates and top ups, no later than 15 months after the last day of the fiscal year; the DGI may extend this to 18 months for the first year. The Executive Branch may designate one Uruguayan entity to file and pay.
Cost to do it: Group level computation and local filing costs.
Example: For a 31 December 2026 year end, the return is due by 31 March 2028, or up to 30 June 2028 if the DGI grants the first year extension. / Fifteen months after year end, eighteen for the first year if extended.Ley Nº 20.446, art. 665 (T.O. 2023 Title 21), Title 21 art. 71, 2025-12-16 official text · verified 2026-10-27
5. Interaction with other taxes: the top up is not deductible for IRAE, is not a liability for the wealth tax, and is not covered by the exemption from national taxes for free zone users. The Executive Branch must set how tax stability guarantees in force when the law was passed fit with the new tax.
Cost to do it: Exemptions that push the Uruguayan rate below 15 percent may be partly clawed back for in scope groups.
Example: A free zone entity of an in scope group with UYU 375,920,472 of excess profit and no IRAE could owe up to UYU 56,388,071. / Up to US$1,402,200 for a fully exempt entity with US$9,348,000 of excess profit.Texto Ordenado 2023 Title 4 and Title 14; Ley Nº 15.921; Ley Nº 20.446, Title 4 art. 35 literal J); Title 14 art. 19; Ley Nº 15.921 art. 20; Ley Nº 20.446 art. 666, 2025-12-16 official text · verified 2026-10-27 · changed: Ley Nº 20.446 art. 636, 643, 664 and 666 adjusted the free zone law, IRAE, IP and stability guarantees for the new tax, from 1 January 2026.
StepUS$UYU
Qualifying income10,000,000402,140,000
Covered taxes (10 percent effective rate)1,000,00040,214,000
Payroll carve out, 9.4 percent of US$3,000,000282,00011,340,348
Tangible asset carve out, 7.4 percent of US$5,000,000370,00014,879,180
Excess profit9,348,000375,920,472
Top up at 5 points (15 minus 10)467,40018,796,024

Illustrative 2026 top up for a Uruguayan entity of an in scope group (UYU at 40.214 per US dollar). Simplified: qualifying income and covered taxes are assumed equal to the figures shown.

Worked example

  • A Uruguayan subsidiary of a European group with 2 billion euros of revenue earns qualifying income of US$10,000,000 (UYU 402,140,000) in 2026, but an investment promotion exemption leaves covered taxes of only US$1,000,000, a 10 percent effective rate.
  • Its payroll is US$3,000,000 and tangible assets US$5,000,000, giving 2026 carve outs of US$652,000 (Title 21 art. 17 and 18). Excess profit is US$9,348,000 and the top up at 5 points is about US$467,400 (UYU 18,796,024).
  • The top up is not deductible for IRAE (Title 4 art. 35 literal J) and the return is due 15 months after year end (Title 21 art. 71).

Step by step

  1. Test the 750 million euro revenue condition on the consolidated statements for the four prior years.
  2. Map Uruguayan entities, including free zone users and permanent establishments, and compute the Uruguayan effective rate.
  3. Compute payroll and tangible asset carve outs with the year's percentages.
  4. Check the de minimis election and any safe harbour the Executive Branch has enabled.
  5. Before applying for or relying on incentives, model whether they push the Uruguayan rate below 15 percent.
  6. Prepare the sworn return within 15 months, or 18 for the first year if the DGI extends it.

Common traps

  • Free zone exemptions do not cover the top up (Ley Nº 15.921 art. 20).
  • Investment promotion IRAE exemptions can be partly offset by the top up for in scope groups.
  • The carve outs fall each year, so the top up base grows over time (Title 21 art. 17 and 18).
  • How existing tax stability agreements interact with the tax depends on Executive Branch rules (Ley Nº 20.446 art. 666).

Sources

Related pages

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