Uruguayan tax law provides that foreign expenses may be deductible in Uruguay only if the payment that originated the expense is subject to foreign taxation in the hands of the foreign recipient.
The Uruguayan tax authorities (DGI) recently issued Resolution 869/009, which adds two conditions for the deductibility of the foreign expenses i.e. (i) the beneficiary of the payment cannot operate, be located or incorporated in a low-tax jurisdiction; and (ii) the foreign tax…