Uruguay

Transfer Pricing in Uruguay

Uruguay transfer pricing (precios de transferencia) for IRAE, tax year 2026, under Título 4 Capítulo VIII (arts. 46 to 58) of the Texto Ordenado 2023, Decreto 56/009 and Decreto 353/018. Covers who is in scope (IRAE taxpayers dealing with related non-residents, professionals in IRAE, anyone dealing with low or no-tax jurisdictions or low-tax free zones), the control test of related parties, the irrebuttable presumption for low-tax jurisdictions (effective rate under 12% and no information exchange), the five methods, the interquartile range and the median plus or minus 5% adjustment, quoted commodities and foreign intermediaries (30% test), contract registration, advance pricing agreements up to three years, the annual form 3001 and study above UI 50,000,000 due in the ninth month, country-by-country and master file for groups of EUR 750 million within 12 months, and the penalty of up to 1,000 times the maximum contravention fine.