• Service: Tax, Global Compliance Management Services, International Tax
  • Type: Regulatory update
  • Date: 9/27/2013

Uruguay - Taxation of public companies transferring to foreign country 

September 27:  Uruguay’s rules concerning the transfer of public companies to a foreign country (and vice-versa) generally provide that companies are no longer subject to Uruguay’s corporate income tax and that legal representation and the corporate name may be retained.

The rules further provide that a public company that is transferred to a foreign location is not subject to Uruguay’s corporate income tax (Impuesto a las Rentas de las Actividades Económicas—IRAE) because the company is no longer a resident of Uruguay (unless the activities in Uruguay constitute a permanent establishment). However, the company could be subject to Uruguay’s tax on non-residents (Impuesto a los no Residentes).

The rules also provide that when a Uruguayan public company transfers to a foreign location, it is not required to terminate its registered legal capacity or corporate name in Uruguay. In such instances, the company would be operating under the foreign country’s rules and regulations, without having to go through liquidation and demerging.

Read a September 2013 report (Spanish) [PDF 116 KB] prepared by the KPMG member firm in Uruguay: La transferencia de domicilio de una sociedad anónima uruguaya al extranjero

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