Countries › Uruguay › Guide › 6. Taxes › Transfer pricing in Uruguay: arm's length rules for cross border related party deals, the UI 50 million filing test, commodity pricing, country by country reporting and penalties

Transfer pricing in Uruguay: arm's length rules for cross border related party deals, the UI 50 million filing test, commodity pricing, country by country reporting and penalties

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

Uruguayan IRAE taxpayers must price transactions with related non residents, and with low taxed entities in free zones and other customs enclaves, at arm's length; any deal with an entity in a low or no tax jurisdiction is presumed related and not at market value. The DGI accepts five methods plus a quoted price rule for commodity imports and exports; prices outside the interquartile range of comparables are adjusted to the median, minus or plus 5 percent. Annual transfer pricing reporting applies when covered operations exceed UI 50 million (about US$8.3 million) or the DGI notifies the taxpayer, groups with consolidated revenue of 750 million euros or more file country by country and master file reports, and formal breaches can cost up to UYU 13.22 million in 2026.

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

Covered operations above which annual transfer pricing reporting is required	50000000 UIResolución DGI Nº 2084/009 numeral 10 (text of Res. 745/011), as of 2026-10-27 · in force
Deadline for annual transfer pricing documentation	Ninth month after fiscal year close Resolución DGI Nº 2084/009, as of 2026-10-27 · in force
Country by country report group revenue threshold	750000000 EURDecreto Nº 353/018, as of 2026-10-27 · in force
Effective rate below which a jurisdiction without information exchange is low or no tax	12 %Decreto Nº 56/009 art. 3, as of 2026-10-27 · in force
Maximum transfer pricing formal breach fine for 2026 (1,000 x UYU 13,220)	13220000 UYULey Nº 17.930 art. 469; Decreto Nº 344/025, 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. Transactions of IRAE taxpayers with related persons or entities are treated as between independent parties when their terms match normal market practice; the rule extends to dealings with foreign subsidiaries, branches and permanent establishments. Relationship exists where both parties are under the direct or indirect direction or control of the same persons through capital, credit, functional influence or otherwise. If terms are not at arm's length, which the DGI must reliably prove, they are adjusted under art. 49.
Cost to do it: Compliance cost of comparability analysis and documentation, set by each provider.
Example: A UYU 40,214,000 sale of services to a foreign affiliate must be priced as with an independent client. / A US$1,000,000 intragroup service contract must carry an arm's length fee.Texto Ordenado 2023 (DGI), Title 4 IRAE, Title 4 art. 46 and art. 47 (Ley Nº 18.083, art. 3), 2006-12-27 official text · verified 2026-10-27

2. Operations with entities resident, domiciled, incorporated or located in low or no tax countries, jurisdictions or special regimes are presumed, without proof to the contrary, to be between related parties and not at market value, including operations with entities in customs enclaves that enjoy low or no taxation. The regulation defines a low or no tax jurisdiction as one taxing Uruguayan source income at an effective rate below 12 percent that has no information exchange agreement or tax treaty with an exchange clause in force with Uruguay, or does not exchange information effectively; the DGI keeps the list.
Cost to do it: Every operation with a listed jurisdiction must be priced and documented under art. 49, whoever the counterparty is.
Example: A UYU 4,021,400 purchase from an unrelated supplier in a listed jurisdiction still needs a transfer pricing analysis. / A US$100,000 purchase from an independent supplier in a listed jurisdiction is treated as a related party deal.Texto Ordenado 2023 (DGI), Title 4 IRAE; Decreto Nº 56/009, Title 4 art. 48; Decreto Nº 56/009 art. 3 (as worded by Decreto Nº 393/019), 2009-01-26 official text · verified 2026-10-27

3. Methods: comparable uncontrolled price, resale price, cost plus, profit split and transactional net margin, applied as the regulation sets. With two or more comparables the taxpayer computes the median and interquartile range; a price inside the range is accepted, and one below the first quartile or above the third is adjusted to the median minus or plus 5 percent respectively.
Cost to do it: The adjustment is taxed at 25 percent IRAE.
Example: If a service fee charged to an affiliate gives a 4 percent margin while the comparable range runs from 6 to 10 percent with a median of 8 percent, the margin is adjusted to 7.6 percent (median minus 5 percent of 8); on costs of UYU 40,214,000 that adds UYU 1,447,704 of income and UYU 361,926 of IRAE. / On US$1,000,000 of costs, the 3.6 point adjustment adds US$36,000 of income and US$9,000 of IRAE.Texto Ordenado 2023 (DGI), Title 4 IRAE; Decreto Nº 56/009, Title 4 art. 49; Decreto Nº 56/009 art. 4 and art. 8, 2009-01-26 official text · verified 2026-10-27

4. Imports and exports of goods with a known international price in transparent markets, made between related parties or through international intermediaries that fail the substance tests, are priced at the quotation on the bill of lading date (the highest quotation for imports, the lowest for exports), or at the contract date if the contract was registered with the DGI within the first five business days of the month after signing.
Cost to do it: Registration is optional; without it the bill of lading date applies.
Example: Soybeans sold to a related trader at UYU 16,085,600 when the lowest quotation on the shipment date implied UYU 16,889,880 are adjusted upward by UYU 804,280. / A US$400,000 export priced US$20,000 below the quoted price is adjusted by US$20,000.Texto Ordenado 2023 (DGI), Title 4 IRAE; Decreto Nº 56/009, Title 4 art. 50 and art. 51; Decreto Nº 56/009 art. 9 BIS, art. 10, art. 13 and art. 13 BIS, 2009-08-24 official text · verified 2026-10-27

5. Annual reporting: taxpayers within Decreto Nº 56/009 must file annual transfer pricing information when their covered operations exceed UI 50,000,000 in the fiscal year, or when the DGI notifies them. Free zone users not taxed by IRAE are excepted from the amount test. The documentation is due by the ninth month after the fiscal year close, and the regulation gives at least eight months to present supporting documentation on request.
Cost to do it: UI 50,000,000 equals about UYU 333,900,000 (US$8,303,079) at the 26 October 2026 UI; preparation of the study is a professional cost.
Example: A company with UYU 400,680,000 of intragroup purchases is above the threshold and must file. / Covered operations above about US$8.3 million trigger the annual filing for a December year end due by the end of September.Resolución DGI Nº 2084/009 numeral 10, as worded by Resolución DGI Nº 745/011; Decreto Nº 56/009, Res. 745/011 numeral 1; Res. 2084/009 numeral 10; Decreto Nº 56/009 art. 14 and art. 15, 2011-05-06 official text · verified 2026-10-27

6. Country by country and master file: IRAE taxpayers that belong to a multinational group with consolidated revenue of at least 750 million euros at the close of the group's fiscal year are subject to the country by country report, unless it is filed by another group entity in a jurisdiction that exchanges it with the DGI; the DGI can also require master file information. The special returns are due within 12 months after the close of the reporting year.
Cost to do it: Group level reporting cost; local notification duties apply.
Example: A Uruguayan SAS of a group with 900 million euros of revenue must file or confirm the parent's filing. / Groups below 750 million euros are outside country by country reporting.Texto Ordenado 2023 (DGI), Title 4 IRAE; Decreto Nº 353/018, Title 4 art. 55 and art. 56; Decreto Nº 353/018, 2018-10-26 official text · verified 2026-10-27

7. Advance pricing agreements may be signed before the transactions they cover, for up to three fiscal years, and bilaterally with other tax administrations under tax treaties in force.
Cost to do it: Negotiation and professional costs.
Example: An APA could fix the margin on UYU 40,214,000 a year of service exports for three years. / An APA can lock in pricing on US$1,000,000 a year of intragroup services for three years.Texto Ordenado 2023 (DGI), Title 4 IRAE, Title 4 art. 53 (Ley Nº 18.996 art. 314; Ley Nº 19.484 art. 65), 2012-11-07 official text · verified 2026-10-27

8. Breaches of transfer pricing formal duties are fined in a graded way under Código Tributario art. 100, under the fine regime of Ley Nº 17.930 art. 469, which allows up to one thousand times the maximum contravention fine of Código Tributario art. 95. For 2026 that maximum is UYU 13,220, so the ceiling is UYU 13,220,000.
Cost to do it: Up to UYU 13,220,000 (about US$328,741) per breach in 2026.
Example: Failing to file the annual report can cost up to UYU 13,220,000. / The ceiling is about US$328,741, before any tax adjustment.Texto Ordenado 2023 (DGI), Title 4 IRAE; Ley Nº 17.930 art. 469 (text by Ley Nº 18.083 art. 68); Decreto Nº 344/025, Title 4 art. 57; Ley Nº 17.930 art. 469; Decreto Nº 344/025 art. 1, 2025-12-30 official text · verified 2026-10-27

Situation	Obligation	Timing
Related party deals with non residents, any amount	Arm's length pricing	Every transaction
Any deal with a low or no tax jurisdiction entity	Presumed related, not at arm's length	Every transaction
Covered operations above UI 50 million, or DGI notice	Annual transfer pricing report	By the ninth month after year end
Group revenue of 750 million euros or more	Country by country and master file	Within 12 months after year end
Quoted commodities with related parties or intermediaries	Quotation at bill of lading or registered contract date	Register within five business days of the next month

Transfer pricing obligations by situation (T.O. 2023 Title 4 art. 46 to 57; Decreto Nº 56/009; Res. DGI 2084/009 and 745/011; Decreto Nº 353/018).

Worked example

A Uruguayan distributor buys UYU 400,680,000 (US$9,963,694) of goods a year from its foreign parent, above the UI 50 million test, so it files the annual transfer pricing report by the ninth month after year end.
Its operating margin is 1 percent while independent distributors earn between 2 and 5 percent with a median of 3.5 percent; the DGI adjusts the margin to 3.325 percent, the median minus 5 percent of the median (Decreto Nº 56/009 art. 8).
On sales of UYU 467,460,000 the adjustment adds about UYU 10,868,445 of income and UYU 2,717,111 (US$67,566) of IRAE, before interest and penalties.

Step by step

Map every transaction with related non residents, free zone or enclave entities with low taxation, and any entity in a low or no tax jurisdiction.
Choose the most appropriate method and build a comparable set; keep results inside the interquartile range.
For quoted commodities, register sale contracts with the DGI within the first five business days of the following month if you want the contract date to govern.
Measure covered operations against UI 50 million at the fiscal year end UI value and file the annual report on time.
If the group's revenue reaches 750 million euros, confirm who files the country by country report and notify the DGI as required.
Consider an advance pricing agreement for large recurring flows.

Common traps

Dealing with any entity in a low or no tax jurisdiction triggers transfer pricing even if it is unrelated, with no proof allowed to the contrary (Title 4 art. 48).
Free zone entities that enjoy low taxation are treated like foreign related parties for transfer pricing (art. 47 and 48).
A price outside the interquartile range is moved to the median adjusted by 5 percent, not to the nearest quartile (Decreto Nº 56/009 art. 8).
Commodity exporters that do not register contracts are priced at the shipment date quotation (Decreto Nº 56/009 art. 13 BIS).
Transfer pricing is applied on top of the 48 percent deduction limit on payments taxed at 12 percent IRNR (Title 4 art. 31).

Sources

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