| Status | Enacted Law |
| Law | Law No. 20446, published January 8, 2026, enacts the DMTT. The signed implementing decree dated October 16, 2026 (S/N/026) provides detailed calculation, election, safe-harbour and compliance rules. A numbered Official Gazette version and publication date have not been independently verified. The decree dated August 31, 2026 replaces the earlier conditional payment waiver in Decree No. 325/025 with compensation; the IMCD obligation remains. DGI Resolution 2400/2026, dated October 23 and published October 26, 2026, prescribes the fiscal-stability compensation procedure under Decree 206/026. A sworn compensation declaration, including the specified tax-secrecy waiver, must precede the administrative file (paragraph 1). The dossier requires protected-entity evidence, group structure, audit substantiation of unavailable foreign credits and the fiscal-year CbCR with prior-year changes identified (paragraph 2). Compensation is linked to the IMCD return; applying it toward payment requires a favourable DGI decision before the tax deadline (paragraph 3). This does not restore the repealed exemption or extend payment deadlines. |
| Effective Date | December 16, 2025 |
| IIR | No |
| UTPR | No |
| QDMTT | Yes |
| Filing Deadlines | 15 months after fiscal year end; DGI may extend first-transition-year filing to 18 months. Designated local filer files and pays for the Uruguay group. |
| Safe Harbours | Detailed — Transitional CbCR Safe Harbour and permanent simplified-calculation/NMCE rules (October 16, 2026 decree, articles 27–36). |
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