Countries › Uruguay › Guide › 6. Taxes › Wealth tax on companies in Uruguay (Impuesto al Patrimonio): 1.5 percent of net equity, which debts count, the IRAE offset and ICOSA

Wealth tax on companies in Uruguay (Impuesto al Patrimonio): 1.5 percent of net equity, which debts count, the IRAE offset and ICOSA

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

Companies and permanent establishments in Uruguay pay the Impuesto al Patrimonio (IP) every year at 1.5 percent of taxable net equity; banks pay 2.8 percent and entities in low or no tax jurisdictions without a local permanent establishment pay 3 percent. Only listed debts reduce the base: loans from Uruguayan banks and financial entities, suppliers' credit, unpaid taxes and listed public debt count, while loans from foreign lenders, including the parent, do not. IRAE paid for the same year reduces the IP bill by up to 50 percent, and the annual ICOSA charge on sociedades anónimas can be credited against IP.

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

Wealth tax (IP) on companies, general rate	1.5 %T.O. 2023 Title 14 art. 53 literal D), as of 2026-10-27 · in force
Wealth tax (IP) on banks and financial houses	2.8 %T.O. 2023 Title 14 art. 53 literal C), as of 2026-10-27 · in force
Wealth tax (IP) on low or no tax jurisdiction entities without a permanent establishment	3 %T.O. 2023 Title 14 art. 53 literal E), as of 2026-10-27 · in force
Maximum reduction of IP by the same year IRAE	50 %T.O. 2023 Title 14 art. 55, as of 2026-10-27 · in force
ICOSA fixed taxable base	578428 UIT.O. 2023 Title 16 art. 2, as of 2026-10-27 · in force
ICOSA rate at each fiscal year close	0.75 %T.O. 2023 Title 16 art. 3, 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. Rates: 1.5 percent for companies and other IRAE taxpayers in art. 4 literal B); 2.8 percent for banks and financial houses; 3.5 percent for bearer bonds and similar securities; 3 percent for entities resident or located in low or no tax jurisdictions that do not act through a permanent establishment. The Executive Branch may cut the rates by up to 50 percent.
Cost to do it: 1.5 percent of taxable net equity a year for an ordinary company.
Example: Taxable net equity of UYU 361,926,000 bears IP of UYU 5,428,890. / US$9,000,000 of taxable net equity bears US$135,000 of IP.Texto Ordenado 2023 (DGI), Title 14 Impuesto al Patrimonio, Title 14 art. 4, art. 53 and art. 54, 2006-12-27 official text · verified 2026-10-27

2. Deductible liabilities for companies are limited to: the monthly average of debts with Uruguayan banks, financial houses, savings and credit cooperatives, credit administrators, closed credit funds and trusts; debts with States, international credit organisations, the CND, ANDE and foreign state financial institutions for long term productive projects; debts with suppliers of goods and services (not loans, placements, guarantees or import price balances); unpaid taxes not yet due; and publicly offered listed bonds. IP itself and the domestic minimum top up tax are not liabilities.
Cost to do it: A loan from a foreign parent or foreign bank does not reduce the base, so it costs 1.5 percent a year of its amount.
Example: Replacing a UYU 160,856,000 parent loan with a local bank loan cuts IP by UYU 2,412,840 a year. / A US$4,000,000 loan from a foreign parent adds US$60,000 a year of IP compared with the same loan from a Uruguayan bank.Texto Ordenado 2023 (DGI), Title 14 Impuesto al Patrimonio, as amended by Ley Nº 20.446, Title 14 art. 19, 2006-12-27 official text · verified 2026-10-27 · changed: Ley Nº 20.446 art. 664 replaced the second paragraph of literal D), adding the domestic minimum top up tax to the items that are not liabilities, from 1 January 2026.

3. Liability absorption: when the company holds foreign assets, exempt assets, excluded or non computable assets, deductible debts are counted only to the extent they exceed the value of those assets.
Cost to do it: Debts that fund exempt or foreign assets give no IP saving.
Example: With UYU 80,428,000 of exempt assets and UYU 40,214,000 of local bank debt, no debt is deducted. / US$1,000,000 of bank debt is fully absorbed by US$2,000,000 of exempt assets.Texto Ordenado 2023 (DGI), Title 14 Impuesto al Patrimonio, Title 14 art. 19 (second paragraph) and art. 21, 2015-12-19 official text · verified 2026-10-27

4. IRAE offset (abatimiento): companies reduce the year's IP by the IRAE generated in the same year, up to 50 percent of the IP; the Executive Branch may lower that percentage.
Cost to do it: Effective IP falls to as little as 0.75 percent of net equity when IRAE is at least half of the IP.
Example: IP of UYU 5,428,890 is cut by UYU 2,714,445 when the year's IRAE is UYU 10,053,500, leaving UYU 2,714,445 to pay. / US$135,000 of IP minus a US$67,500 IRAE offset leaves US$67,500.Texto Ordenado 2023 (DGI), Title 14 Impuesto al Patrimonio, Title 14 art. 55 (Ley Nº 18.083 art. 49), 2006-12-27 official text · verified 2026-10-27

5. Sociedades anónimas also pay the Impuesto de Control de las Sociedades Anónimas (ICOSA) on a fixed base of UI 578,428, valued at the UI of 31 December of the prior year: 1.5 percent at incorporation and 0.75 percent at each fiscal year close. The year end ICOSA can be credited against that year's IP, without refund of any excess.
Cost to do it: For 2026 events, UI 578,428 at UYU 6.4234 (BCU, 31 December 2025) gives a base of UYU 3,715,474: UYU 55,732 at incorporation and UYU 27,866 at each year end.
Example: Year end ICOSA of UYU 27,866 is credited against IP. / About US$1,386 at incorporation and US$693 each year end, at the 26 October 2026 rate.Texto Ordenado 2023 (DGI), Title 16 ICOSA, Title 16 art. 1 to art. 4, 2002-05-29 official text · verified 2026-10-27

6. Promoted investment projects under Ley Nº 16.906 get an IP exemption on movable assets in the eligible investment for their whole useful life, and on promoted civil works for 8 years in Montevideo or 10 years in the interior.
Cost to do it: Requires a promotional declaration; see Tax incentives.
Example: Machinery of UYU 40,214,000 in a promoted project saves UYU 603,210 of IP a year before the IRAE offset. / US$1,000,000 of promoted equipment saves US$15,000 of IP a year.Decreto Nº 329/025 (investment promotion regulation), Art. 18, 2025-12-23 official text · verified 2026-10-27

Step	Parent loan structure (US$)	Local bank structure (US$)
Taxable assets	10,000,000	10,000,000
Deductible liabilities	1,000,000	5,000,000
Taxable net equity	9,000,000	5,000,000
IP at 1.5 percent	135,000	75,000
IRAE offset (IRAE US$250,000, cap 50 percent of IP)	67,500	37,500
IP payable	67,500	37,500

IP of a company with US$10,000,000 of taxable assets, funded by a US$4,000,000 parent loan and a US$1,000,000 local bank loan, compared with funding both through local banks (UYU at 40.214 per US dollar).

Worked example

A Uruguayan S.A. has US$10,000,000 (UYU 402,140,000) of taxable assets at year end, funded with a US$4,000,000 loan from its foreign parent and a US$1,000,000 loan from a Montevideo bank.
Only the bank loan is deductible (Title 14 art. 19), so taxable net equity is US$9,000,000 and IP is US$135,000 (UYU 5,428,890).
The company's IRAE for the year is US$250,000, so it reduces IP by the cap of 50 percent, US$67,500, and pays US$67,500 (UYU 2,714,445) (art. 55); the year end ICOSA it paid is also creditable against IP (Title 16 art. 4).
Had both loans come from Uruguayan banks, IP would have been US$75,000 before the offset and US$37,500 after it.

Step by step

Value assets under the IP valuation rules at fiscal year end.
List liabilities and keep only those in art. 19; request the year end balance certificates that local lenders must issue within 90 days.
Reduce deductible debts by any foreign, exempt or non computable assets (art. 19 and 21).
Apply 1.5 percent and deduct the same year's IRAE up to 50 percent of IP, then credit the year end ICOSA if the company is an S.A.
If the project is promoted under Ley Nº 16.906, exclude the exempt assets and remember they still absorb liabilities unless the rule says otherwise.

Common traps

Funding a Uruguayan subsidiary with intragroup or foreign bank debt does not reduce the IP base, unlike local bank debt (Title 14 art. 19).
Exempt or foreign assets absorb deductible liabilities, so borrowing locally to buy exempt assets gives no IP saving (art. 19 and 21).
A company in a low or no tax jurisdiction that holds Uruguayan assets directly pays 3 percent, double the ordinary rate (art. 53 literal E).
ICOSA is due even when the S.A. has no activity, and only the year end charge, not the incorporation charge, is creditable against IP (Title 16 art. 3 and 4).

Sources

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