Uruguay Enacts DMTT Law and issues a Decree for Exemptions under Tax Stability Agreements

On January 8, 2026, Law No. 20446 was published in the Official Gazette. This introduces a new Title 21 into the Consolidated Tax Law for a domestic minimum top-up tax (DMTT). Article 3 of Law No. 20446 provides that this applies from January 1, 2026.

The Law does not include an income inclusion rule (IIR) or an under-taxed profits rule (UTPR).  

On December 29, 2025, Uruguay’s President issued Decree No. 325/025, to provide for exemptions from the DMTT for entities covered by a tax stability agreement.

General

Whilst the Law uses the same approach as the OECD Model Rules (with the same approach to the effective tax rate calculation, jurisdictional blending and GloBE income/Adjusted Covered Tax adjustments), as the Law only provides for the DMTT (and not an IIR or UTPR), it is specifically tailored to Uruguay’s domestic tax regime with a number of elements in the general GloBE rules not applicable for DMTT purposes.

Article 74 of the Law states that it is intended to be compatible with the OECD Model Rules and Guidance and the Government intends to apply the Law so that it is implemented  and administered in a manner that is consistent OECD rules.

It also notes that the Government will suspend the tax if the GloBE rules are repealed or suspended by the OECD.

As noted below, very few aspects of the OECD Administrative Guidance are included in the Law.