Countries › Uruguay › Guide › 6. Taxes › Tax incentives in Uruguay: the 2026 investment promotion regime (COMAP), free zones, the software and biotech exemption and how the minimum tax interacts

Tax incentives in Uruguay: the 2026 investment promotion regime (COMAP), free zones, the software and biotech exemption and how the minimum tax interacts

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

Under Ley Nº 16.906 and Decreto Nº 329/025, in force since 1 February 2026, projects declared promoted get an IRAE exemption equal to a percentage of the eligible investment set by a scoring matrix, capped at 100 percent of the investment and 90 percent of each year's tax, used over at least four years. Promoted projects also get wealth tax exemptions, duty and IVA free imports of non competitive capital goods and IVA refunds on local construction purchases, with extra points for small and medium firms, industrial parks and very large projects above UI 180 million. Free zone users are exempt from national taxes, and software, biotech and bioinformatics income is exempt in whole or in part under Title 4 art. 66 literal S); large multinational groups must check the 15 percent domestic minimum tax, which applies even in free zones.

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

Maximum share of each year's IRAE that the promotion exemption can cover	90 %Decreto Nº 329/025 art. 16, as of 2026-10-27 · in force
Minimum IRAE exemption term for promoted projects	4 fiscal yearsDecreto Nº 329/025 art. 17, as of 2026-10-27 · in force
Eligible investment above which a 100 percent IRAE exemption is available (filed before 31 December 2027)	180000000 UIDecreto Nº 329/025 art. 20, as of 2026-10-27 · in force
COMAP review period before a deemed recommendation	90 business daysDecreto Nº 329/025 art. 8 and art. 9, as of 2026-10-27 · in force
Share of direct costs in Uruguay for full software services exemption (more than)	50 %T.O. 2023 Title 4 art. 66 literal S), as of 2026-10-27 · in force
Free zone users and national taxes	Exempt, except social security and the domestic minimum top up tax Ley Nº 15.921 art. 19 and art. 20, 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 Executive Branch may declare promoted the investment projects of companies, and specific sector activities, taking into account investments that bring technical progress, raise and diversify exports, create productive jobs, integrate local value chains, support micro, small and medium firms, decentralise activity, and hire afro descendant or trans staff.
Cost to do it: Application through the COMAP; professional preparation costs.
Example: A plant expansion of UYU 201,070,000 can be submitted for promotion. / A US$5,000,000 project can apply.Ley Nº 16.906, Art. 11, 1998-01-07 official text · verified 2026-10-27

2. Promoted projects get an IRAE exemption for a percentage of the eligible investment that results from the scoring matrix (employment, decentralisation, exports, environmental sustainability, technology and R&D, and sector indicators). In each year the exempt IRAE cannot exceed 100 percent of the amount actually invested nor 90 percent of the tax payable. The COMAP sets the term, never less than four fiscal years, counted from the first year with taxable income if within four years of the declaration; the company may suspend it for up to two years.
Cost to do it: Benefit equals the matrix percentage of eligible investment, within the 90 percent annual cap.
Example: A project investing UYU 201,070,000 with a 40 percent score can exempt up to UYU 80,428,000 of IRAE over its term. / A 40 percent score on US$5,000,000 gives up to US$2,000,000 of IRAE exemption; with US$500,000 of annual IRAE, at most US$450,000 can be exempted in a year.Decreto Nº 329/025, Art. 5, art. 16 and art. 17, 2025-12-23 official text · verified 2026-10-27

3. Other benefits for promoted projects: wealth tax exemption on movable assets of the eligible investment for their useful life and on promoted civil works for 8 years in Montevideo or 10 years elsewhere; full exemption of import taxes and IVA on movable fixed assets and civil works materials declared non competitive; and refund of IVA on local purchases of materials and services for the civil works and movable assets.
Cost to do it: No fee; the benefits follow the promotional resolution.
Example: UYU 40,214,000 of promoted equipment saves UYU 603,210 of wealth tax a year. / US$1,000,000 of promoted equipment saves US$15,000 of IP a year and the import taxes on it.Decreto Nº 329/025, Art. 18, 2025-12-23 official text · verified 2026-10-27

4. Micro and small firms get 15 extra percentage points of IRAE benefit and two more years; medium firms with up to 50 employees get 10 points and one more year. Projects with eligible investment above UI 180,000,000 can get a 100 percent IRAE exemption if filed before 31 December 2027 and fully executed before 31 December 2029; above UI 300,000,000 if filed before 31 December 2028 and executed before 31 December 2031, subject to minimum scores. Users of industrial and science parks get 15 percent more benefit and term for industrial and listed activities (5 percent for others).
Cost to do it: UI 180,000,000 is about UYU 1,202,040,000 (US$29,891,083) at the 26 October 2026 UI.
Example: A UYU 402,140,000 project above UI 180 million filed in 2027 can exempt IRAE up to the full investment. / A US$10,000,000 project above the UI 180 million line can shelter up to US$10,000,000 of IRAE, within the 90 percent annual cap.Decreto Nº 329/025, Art. 19, art. 20 and art. 21, 2025-12-23 official text · verified 2026-10-27

5. Procedure: the COMAP has 90 business days from formal validation of the application to recommend; if it does not, it is deemed to recommend the benefits. Beneficiaries report within four months of each year end, and breaches lead to reliquidation of exempted taxes. The decree took effect on 1 February 2026; projects filed between 1 August 2025 and 31 January 2026 could opt into it, and filings under the previous decree were possible until 30 April 2026. Pending a resolution, the company may self apply the requested IRAE and IP benefits and pay any shortfall without penalties within three months of the resolution.
Cost to do it: Annual reporting to the COMAP; tax reliquidation on breach.
Example: A project filed on 1 March 2026 should get a recommendation within 90 business days of validation. / Self application of benefits while the file is pending is allowed with a three month cure window.Decreto Nº 329/025, Art. 8, art. 9, art. 10, art. 11, art. 22 and art. 23, 2025-12-23 official text · verified 2026-10-27

6. Free zone users are exempt from all national taxes, existing or future, for activities within their authorisation; social security contributions and the domestic minimum top up tax are excluded from the exemption, and foreign staff can opt out of Uruguayan social security in writing. Income from intellectual property is exempt only when it comes from R&D carried out in the free zone, in the proportion of direct costs (plus 30 percent) to total costs.
Cost to do it: Exemption from IRAE, IVA, IP and other national taxes for authorised activities.
Example: A free zone services company with UYU 40,214,000 of profit pays no IRAE, saving UYU 10,053,500. / On US$1,000,000 of free zone profit, US$250,000 of IRAE is avoided, but in scope groups may owe the 15 percent domestic minimum tax.Ley Nº 15.921, Art. 19 and art. 20 (as worded by Ley Nº 19.566 and Ley Nº 20.446 art. 636), 2025-12-16 official text · verified 2026-10-27 · changed: Ley Nº 20.446 art. 636 reworded art. 20 paragraph one to exclude the domestic minimum top up tax, from 1 January 2026.

7. Software, biotech and bioinformatics: income from R&D in those fields and from software production is exempt in the proportion of direct costs (plus 30 percent, capped at total costs) to total costs, when the resulting assets are protected and registered as intellectual property; income from services in those fields, including software development, is fully exempt when more than 50 percent of the direct costs are incurred in Uruguay. A sworn statement to the DGI and notes on invoices are required.
Cost to do it: Sworn statement and documentation duties.
Example: A software services firm with UYU 40,214,000 of profit and 70 percent of direct costs in Uruguay is fully exempt, saving UYU 10,053,500. / US$250,000 of IRAE avoided on US$1,000,000 of qualifying software services profit.Texto Ordenado 2023 (DGI), Title 4 IRAE, Title 4 art. 66 literal S), 2017-09-25 official text · verified 2026-10-27

Regime	Main benefit	Key condition
Investment promotion (COMAP)	IRAE exemption of a matrix percentage of investment; IP, import and IVA benefits	Promotional declaration; 90 percent annual IRAE cap
Large projects above UI 180 million	Up to 100 percent of eligible investment	Filed by 31 December 2027 and executed by 31 December 2029
Large projects above UI 300 million	Up to 100 percent of eligible investment	Filed by 31 December 2028 and executed by 31 December 2031
Free zones	Exemption from national taxes	Authorised activities; not social security or minimum top up tax
Software and biotech services	Full IRAE exemption	More than 50 percent of direct costs in Uruguay
Software and biotech assets	Proportional IRAE exemption	Registered IP; cost ratio formula

Main incentive regimes for foreign investors (Ley Nº 16.906 and Decreto Nº 329/025; Ley Nº 15.921; T.O. 2023 Title 4 art. 66 literal S).

Worked example

A food processor plans a US$5,000,000 (UYU 201,070,000) plant in Paysandú and files with the COMAP in 2026 under Decreto Nº 329/025. Its matrix score gives an IRAE exemption of 40 percent of the eligible investment, US$2,000,000, over at least four years (art. 16 and 17).
In a year with US$500,000 of IRAE it can exempt at most US$450,000 (90 percent) and no more than it has actually invested by then. Its civil works are IP exempt for 10 years because the plant is outside Montevideo, and imported equipment declared non competitive enters free of import taxes and IVA (art. 18).
If the company belongs to a group with 750 million euros of revenue, it should model whether the exemption pushes its Uruguayan effective rate below 15 percent and triggers the domestic minimum top up tax (see Global minimum tax).

Step by step

Define the eligible investment (fixed assets, intangibles, civil works, biological assets) and its schedule.
Score the project on the matrix indicators and decide which commitments are realistic.
File with the COMAP, then track the 90 business day review.
Report within four months of each year end and keep promoted assets for their useful life.
For free zones or software regimes, confirm the authorisation scope or cost tests and keep the documentation.

Common traps

The IRAE benefit is capped each year at 90 percent of the tax and at what has actually been invested (Decreto Nº 329/025 art. 16).
Missing committed indicators or selling promoted assets early triggers reliquidation of exempted taxes (art. 11 and 12).
Investments that already enjoy IRAE exemptions under other regimes, or that are publicly subsidised, are not eligible (art. 3).
Free zone and promotion exemptions do not protect in scope multinational groups from the 15 percent domestic minimum top up tax (Ley Nº 15.921 art. 20; Ley Nº 20.446 art. 665).
The software exemption for assets requires registered intellectual property and is reduced by costs paid to related non residents (Title 4 art. 66 literal S).

Sources

Related: Uruguay country profile · live dashboard · central bank and release calendar · our posts on X · where Argentina is involved, see The Argentine Thread guide

← Import taxes in Uruguay: the 5 percent consular fee, 3 percent for Mercosur goods, IVA and its import advance, and exemptions for promoted projects and free zonesUruguay'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 →