Uruguay

Cross Border in Uruguay

Uruguay cross-border tax for 2026: the non-resident income tax (IRNR, Impuesto a las Rentas de los No Residentes) in Título 8 of the Texto Ordenado 2023 as amended by Ley 20.446, and its regulation Decreto 149/007. Covers who is resident (183 days, centre of interests, companies formed under Uruguayan law), what is Uruguayan-source income (technical services to IRAE payers, digital services, share sales of foreign entities holding Uruguayan assets from 2026), the IRNR rates (12% general, 7% dividends, 25% low or no-tax jurisdictions, reduced rates on local interest), the withholding rates and the gross-up for net payments, exemptions, the duty to appoint a representative, form 1246, and treaty relief under Uruguay's 25 double tax treaties in force.