The new decree requires ultimate beneficial owners to maintain at least 95% (instead of 5%) of their equity proportions for at least two years to not consider goodwill in corporate restructurings.
In Decree 64/021, Uruguay's Executive Power repealed Decree 21/021(see EY Global Tax Alert, Uruguay modifies when goodwill is not considered in corporate restructurings, dated 11 February 2021), modifying the requirements that taxpayers must meet to not consider goodwill in mergers or spin-offs that are…