Global

Details

  • Service: Tax, International Corporate Tax, Global Compliance Management Services
  • Type: Regulatory update
  • Date: 6/20/2012

Uruguay - Payments for software subject to nonresident’s tax 

June 20:  Uruguay’s tax administration issued an opinion finding that certain payments made to foreign companies producing software, but not having a permanent establishment in Uruguay, are subject to the nonresident’s tax.

The Dirección General de Impuestos issued consultation N° 5527, which provides that income related to software licensing agreements, received by foreign companies not having a permanent establishment in Uruguay, is subject to the nonresident's tax (Impuesto sobre la Renta de No Residentes—IRNR). However, certain software related to the purchase of equipment is not subject to the IRNR.


Read a June 2012 report (Spanish) [PDF 58 KB), prepared by the KPMG member firm in Uruguay: Pagos al exterior por licencias de software y multas- IRNR




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