Uruguay · Tax regime
Tax Holiday for New Tax Residents
Substantially rewritten by Ley 20.446 (Presupuesto Nacional 2025–2029) with effect from 1 January 2026. The holiday is 11 years (year of arrival plus ten). The investment gateway was repriced from roughly USD 590k of real estate to UI 12.5 million (~USD 2m), the old 60-day presence route was removed, and foreign immovable-capital income and capital gains became taxable for residents outside the holiday.
Eleven years of zero tax on foreign passive income, in a stable, bankable, CRS-compliant jurisdiction with no wealth tax on foreign assets, is the best long-horizon holiday in the Americas — longer than Italy's, cleaner than Portugal's. Ley 20.446 made the runway longer and the entry price higher at the same time: this is now explicitly a regime for the wealthy.
Qualifying routes
more than 183 days per year — no investment required, but this is now the only presence-based gateway; the previous 60-day route was eliminated
UI 12,500,000 — approximately USD 2 million; up from roughly USD 590,000 (UI 3.5m) under the prior Decreto 163/020 regime
UI 625,000 per year — approximately USD 100,000 annually into funds financing productive projects, research or applied innovation
The facts
- Qualifying figure
- $2M
- Total landed cost
- no fee for the election itself; the cost is the qualifying investment plus advisory. Uruguayan legal and tax structuring for a family typically runs USD 15–40k.
- Timeline
- 1–12 months — the election is made once; obtaining a DGI tax residency certificate takes a few months
- Physical presence
- 183+ days if using the presence gateway. The investment gateways do not require 183 days to qualify for the holiday, but you still need to be a tax resident for the holiday to mean anything.
- Family
- the election is individual — each spouse elects separately and each needs their own qualifying basis
- Permanent residency
- not applicable — this is a tax regime; legal residency is a separate track
- Citizenship
- not applicable
- Language test
- not applicable
- Dual citizenship
- Permitted
- Requirements
- become a Uruguayan tax resident (183+ days, or centre of economic/vital interests plus a qualifying investment)not have been a Uruguayan tax resident in the preceding fiscal yearsnot have previously elected the holidaymake the election with the DGI
- The regime changed materially on 1 January 2026 and the reform cuts both ways. From that date, foreign immovable-capital income and capital gains on assets producing movable-capital yields are Uruguayan-taxable at 12% for residents who are NOT inside a holiday. Uruguay is no longer the simple territorial jurisdiction its reputation suggests.
- A new tax-transparency rule attributes income and gains of foreign non-resident entities directly to Uruguayan beneficial owners holding 5% or more, regardless of distribution. Offshore holding structures no longer defer anything — this is the sleeper provision of the reform.
- The real estate gateway more than tripled, from roughly USD 590k to about USD 2m. The 60-day presence route is gone. If you were planning against the old numbers, the plan is void.
- You must not have been a Uruguayan tax resident in the preceding fiscal years and must not have used the holiday before. It is once per lifetime.
- After the holiday the choice is a ~6% rate for five years (subject to its own investment conditions — roughly USD 1m of real estate or USD 100k/year) or a fixed annual IRPF amount reported at roughly USD 300,000 (about USD 200,000 with 183+ days presence) for twenty years. Model the exit before you model the entry; for very large portfolios the fixed-sum option may be the point of the whole exercise.
- The mechanics of the credit for foreign taxes paid were still awaiting implementing regulations as of mid-2026.
- Uruguay has no double-tax treaty with the United States. US citizens get the holiday's benefit only to the extent US tax does not simply reclaim it.