Uruguay’s Tax Authority clarifies tax treatment of profit repatriations paid by a permanent establishment under double tax treaty

08 August 2022|Tax Alerts, Legislation & Policy, National/Federal Taxation, Treaties|Uruguay

The Uruguayan Tax Authority (Dirección General Impositiva, DGI) has confirmed that profit repatriations received by the head office from its permanent establishment (PE) in Uruguay are not subject to nonresident income tax (NRIT).

In Consultation No. 6490, Uruguay’s DGI concluded Article 7 (Business Profits) of the Uruguay-Belgium double tax treaty applies to profit repatriations from a PE to its head office. The DGI explained that Article 10 (Dividends) refers to dividends paid from a resident o…

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