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Uruguay's tax treaties: 25 agreements in force, treaty caps on dividends, interest and royalties, and when they beat domestic IRNR rates

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

The DGI lists 25 agreements in force to avoid double taxation, from Germany, Spain, Mexico, Chile and Brazil to Japan, the United Kingdom and Switzerland; the one with Argentina is an information exchange agreement with a method to avoid double taxation, and a treaty with Colombia is signed but not in force. Because Uruguay's domestic IRNR is already low (7 percent on dividends), treaties matter mainly where they cap interest and royalties at 10 percent instead of 12 percent, or dividends at 5 percent for qualifying corporate shareholders. The texts are consolidated in Title 2 of the Texto Ordenado 2023 together with the multilateral instrument (MLI) approved by Ley Nº 19.814, the Convention on Mutual Administrative Assistance and 15 bilateral information exchange agreements.

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

Agreements to avoid double taxation in force (DGI list)25 agreementsDGI state of agreements, as of 2026-10-27 · in force
Treaties signed but not in forceColombia (signed 19 November 2021) DGI state of agreements, as of 2026-10-27 · in force
Uruguay Argentina tax agreement in force from7 February 2013 dateLey Nº 19.032, as of 2026-10-27 · in force
Uruguay Spain treaty dividend cap (exempt for a company with 75 percent)5 %Ley Nº 18.730, treaty art. 10, as of 2026-10-27 · in force
Uruguay Mexico treaty interest cap10 %Ley Nº 18.645, treaty art. 11, as of 2026-10-27 · in force
Uruguay Brazil treaty interest cap15 %Ley Nº 20.009, treaty art. 11, 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. Agreements to avoid double taxation in force, with the date from which they apply to taxes, per the DGI: Germany (2012), Argentina (2013), Belgium (2018), Brazil (2024), Chile (2019), Korea (2014), Ecuador (2013), United Arab Emirates (2017), Spain (2012), Finland (2014), Hungary (1994), India (2014), Italy (2021), Japan (2022), Liechtenstein (2013), Luxembourg (2018), Malta (2013), Mexico (2011), Paraguay (2020), Portugal (2012), United Kingdom (2017), Romania (2015), Singapore (2018), Switzerland (2012) and Vietnam (2017). The agreement with Colombia was signed on 19 November 2021 and is listed as not yet in force.
Cost to do it: No filing fee; the recipient must evidence treaty residence and beneficial ownership.
Example: A Japanese parent receiving UYU 40,214,000 of dividends from a 10 percent or larger holding can have Uruguayan tax capped at 5 percent, UYU 2,010,700, instead of the domestic 7 percent. / On a US$1,000,000 dividend, a 5 percent treaty cap saves US$20,000 against the 7 percent domestic rate.DGI, state of the agreements to avoid double taxation; approving laws listed in the table, Each approving law (single article) and the treaty's entry into force clause, 2024-04-25 official text · verified 2026-10-27
2. Typical caps in Uruguay's treaties: interest 10 percent (15 percent in the treaties with Brazil, Ecuador, Hungary and Paraguay); royalties 10 percent (5 percent for copyright royalties under the Spain treaty; 15 percent under the Paraguay treaty); dividends 5 percent for qualifying corporate shareholders in many treaties, with higher caps for others. Where the domestic rate is lower than the treaty cap, as with the 7 percent dividend IRNR against a 15 percent cap, the domestic rate applies.
Cost to do it: The treaty saving on interest or royalties is 2 points of the gross payment where the cap is 10 percent.
Example: Royalties of UYU 4,021,400 paid to a UK licensor bear UYU 402,140 under the treaty instead of UYU 482,568. / US$100,000 of royalties to a UK or Mexican licensor: US$10,000 of tax under the treaty instead of US$12,000.Texto Ordenado 2023 (DGI), Title 2 (international tax law), Section I, Art. 10, 11 and 12 of each consolidated treaty, 2024-04-25 official text · verified 2026-10-27
3. Spain: dividends are capped at 5 percent, and are exempt in the source State when paid to a company that directly holds at least 75 percent of the capital of the payer, subject to the treaty's conditions; interest is capped at 10 percent and royalties at 5 percent for copyright on literary, artistic or scientific works and 10 percent in other cases.
Cost to do it: Exemption or reduced cap on application of the treaty.
Example: A dividend of UYU 40,214,000 to a Spanish parent holding 75 percent can be exempt instead of bearing UYU 2,814,980. / Up to US$70,000 saved on a US$1,000,000 dividend.Ley Nº 18.730 (Uruguay Spain agreement), consolidated in T.O. 2023 Title 2 Chapter X, Treaty art. 10, 11 and 12, 2011-04-24 official text · verified 2026-10-27
4. Mexico and India: dividends capped at 5 percent for any beneficial owner resident in the other State; interest and royalties at 10 percent.
Cost to do it: Reduced withholding on application of the treaty.
Example: Interest of UYU 4,021,400 to a Mexican lender bears UYU 402,140. / US$100,000 of interest to a Mexican lender: US$10,000 instead of US$12,000.Ley Nº 18.645 (Mexico) and Ley Nº 18.972 (India), consolidated in T.O. 2023 Title 2 Chapters XIX and XIII, Treaty art. 10, 11 and 12, 2010-12-29 official text · verified 2026-10-27
5. Brazil (applying from 1 January 2024): dividends capped at 10 percent for a company holding at least 25 percent of the payer's capital for 365 days and 15 percent otherwise, and interest at 15 percent, both above Uruguay's domestic rates of 7 and 12 percent, so Uruguayan domestic law gives the lower rate.
Cost to do it: No saving on Uruguayan withholding; the treaty matters for the Brazilian side and other articles.
Example: Interest of UYU 4,021,400 to a Brazilian lender bears the domestic 12 percent, UYU 482,568. / US$100,000 of interest to a Brazilian lender: US$12,000 under domestic law.Ley Nº 20.009 (Uruguay Brazil agreement), consolidated in T.O. 2023 Title 2 Chapter V, Treaty art. 10 and 11, 2023-07-21 official text · verified 2026-10-27
6. Argentina: the agreement signed in Colonia on 23 April 2012 covers exchange of tax information and a method to avoid double taxation; it is listed by the DGI as in force from 7 February 2013. Uruguay withholds its domestic IRNR on payments to Argentine residents; relief on the Argentine side is an Argentine law question.
Cost to do it: No Uruguayan filing cost; Argentine advice is separate.
Example: A UYU 40,214,000 dividend to an Argentine parent bears UYU 2,814,980 of IRNR. / US$1,000,000 dividend, US$70,000 withheld in Uruguay; see The Argentine Thread guide for the Argentine side.Ley Nº 19.032, consolidated in T.O. 2023 Title 2 Chapter III, Single article approving the agreement, 2013-02-07 official text · verified 2026-10-27
CountryApproving lawIn forceApplies fromDividendsInterestRoyalties
GermanyLey Nº 18.84428 December 20111 January 20125 (company with 10 percent) / 151010
ArgentinaLey Nº 19.0327 February 20137 February 2013Information exchange agreement with a method to avoid double taxation; see The Argentine Thread
BelgiumLey Nº 19.4034 August 20171 January 20185 (company with 10 percent for 365 days) / 151010
BrazilLey Nº 20.00921 July 20231 January 202410 (company with 25 percent for 365 days) / 1515Not shown
ChileLey Nº 19.5485 September 20181 January 2019Not shown1010
KoreaLey Nº 19.03322 January 20131 January 2014Not shown1010
EcuadorLey Nº 18.93215 November 20121 January 2013Not shown15Not shown
United Arab EmiratesLey Nº 19.39313 June 20161 January 20175 (company) / 710Not shown
SpainLey Nº 18.73024 April 20111 January 20125; exempt for a company with 75 percent105 (copyright) / 10
FinlandLey Nº 19.0356 February 20131 January 2014Not shown10Not shown
HungaryLey Nº 16.36613 August 19931 January 19941515Not shown
IndiaLey Nº 18.97221 June 20131 January 201451010
ItalyLey Nº 19.8199 October 20201 January 20215 (company with 10 percent) / 151010
JapanLey Nº 19.93823 July 20211 January 20225 (non individual with 10 percent) / 101010
LiechtensteinLey Nº 18.9333 September 20121 January 2013Not shown1010
LuxembourgLey Nº 19.35411 January 20171 January 20185 (company with 10 percent) / 1510Not shown
MaltaLey Nº 19.01013 December 20121 January 2013Not shown10Not shown
MexicoLey Nº 18.64529 December 20101 January 201151010
ParaguayLey Nº 19.69730 March 20191 January 2020Not shown1515
PortugalLey Nº 18.93413 September 201213 September 20125 (company with 25 percent for 365 days) / 101010
United KingdomLey Nº 19.44314 November 20161 January 20175 (company with 10 percent) / 151010
RomaniaLey Nº 19.25722 October 20141 January 2015Not shown1010
SingaporeLey Nº 19.45714 March 20171 January 20185 (company with 10 percent) / 1010Not shown
SwitzerlandLey Nº 18.86728 December 20111 January 2012Not shown1010
VietnamLey Nº 19.40426 July 20161 January 2017Not shown1010

Agreements in force per the DGI (in force date and date of application to taxes) and Uruguayan source caps read from the consolidated texts in T.O. 2023 Title 2 (percent of gross payment). 'Not shown' means the cap was not extracted for this page; read the treaty before applying it.

Worked example

  • A German company owning 100 percent of a Uruguayan SAS receives a dividend of UYU 40,214,000 (US$1,000,000). Domestic IRNR is 7 percent, UYU 2,814,980; the Germany treaty caps it at 5 percent for a company holding at least 10 percent, UYU 2,010,700 (US$50,000).
  • The SAS also pays US$100,000 (UYU 4,021,400) of royalties to the parent: 10 percent under the treaty, US$10,000, instead of 12 percent.
  • For an Argentine parent no such caps apply in Uruguay: the 7 and 12 percent domestic rates are withheld, and relief is claimed in Argentina under the 2012 agreement (see The Argentine Thread guide).

Step by step

  1. Check the DGI table to confirm the treaty is in force and applies to the relevant year.
  2. Obtain a tax residence certificate from the recipient and confirm it is the beneficial owner.
  3. Read the treaty article (10, 11 or 12) and the holding and period conditions, and check any changes made by the multilateral instrument (Ley Nº 19.814).
  4. Compare the treaty cap with the domestic IRNR rate and apply the lower one.
  5. Keep the documentation with the withholding records for the five year limitation period.

Common traps

  • The United States does not appear in the DGI list of agreements in force, so US recipients get domestic IRNR rates.
  • Several treaty caps exceed Uruguay's domestic rates (dividends 15 percent, Brazil interest 15 percent); treaties never raise the domestic rate.
  • Dividend caps of 5 percent usually need a minimum holding (10, 25 or 75 percent) and sometimes a 365 day holding period.
  • The Argentina agreement is not a full model treaty; do not assume model treaty caps on Argentine payments.

Sources

Related pages

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

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