Uruguayan President’s Office issued a decree at the end of December 2025 that exempts certain multinational group entities from Uruguay’s domestic complementary minimum tax under OECD Pillar Two. The exemption applies to entities protected by a fiscal stability clause, where the tax already paid in Uruguay is higher than the amount due under the global minimum tax rules or cannot be credited abroad. This includes, among others, free trade zone users and forestry operators. If an entity has already paid the minimum tax but qualifies for the exemption, it may request a refund through an administrative procedure. To benefit, taxpayers must formally apply and allow the exchange of information within the BEPS inclusive framework.
To read more on the Exemptions, click here.