Uruguay's New Rules on Dividend Withholding Tax and Taxation of Indirect Transfers

As part of Uruguay's National Budget for 2025-2029 (Law No. 20446 of 16 December 2025). Uruguay introduced new rules regarding withholding tax on dividends and the taxation of indirect transfer of Uruguayan assets.

Tax is generally withheld at the rate of 7% from gross dividends distributed to non-residents when paid out of profits subject to corporate tax (IRAE), unless reduced by a tax treaty, which is unchanged. When paid out of profits from non-taxable income, an exemption from withhold…