Uruguay has published DGI Resolution No. 488/023 in the Official Gazette, which clarifies certain aspects of the new rules on taxable Uruguay-source passive income introduced by Law 20.095 (previous coverage). The key points are summarized as follows:
- Income derived from trademarks that are sold or used outside of Uruguay by taxpayers that are part of a multinational group is always considered Uruguayan source income, regardless of whether the taxpayer is a qualified entity with adequate e…