Once a “tax holiday” election is made, a taxpayer may only have the election revoked if there was a fact or law error at the time of the election.
The Uruguayan tax authorities have ruled (Consultation No. 6369) that a taxpayer who elected to participate in the “tax holiday” regime must remain in the regime because the taxpayer could not show that there was a fact or law error when the election was made.
The taxpayer acquired tax residence in Uruguay during 2017 and joined the “tax holiday” regim…