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12.4.4. APAs and Dispute Resolution Mechanisms

Advance Pricing Agreements (APAs)

Unilateral, bilateral or multilateral APAs are available in Uruguay. They must be applied for prior to a transaction, and are generally applicable for up to 3 years.

Mutual Agreement Procedure (MAPs)

Tax treaties concluded by Uruguay contain a MAP clause, whereby the Competent Authorities of the Contracting states may consult with each other with a view to resolving instances of (double) taxation not in line with the Convention. There is, however, to date no domestic regulations in Uruguay for MAP.


If an adjustment is proposed by the tax authority, the taxpayer has the right to appeal through the same appeals process for other tax adjustments/assessments (see Sec. 13.7.).