GloBE Country Guide: Uruguay

Summary

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.
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).

Legislation
General
Differences to Model Rules
Qualifying Domestic Minimum Top-Up Tax
Administration and Filing
Penalties

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Lee Hadnum

Lee is a qualified Chartered Accountant and a former Senior Tax Analyst at Bloomberg Tax. Lee began his career in Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience.

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