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12.3.1. Main Rules

There are no CFC rules, other than certain specific provisions applicable to resident individuals. As a measure to counter tax evasion and promote tax transparency, the Uruguayan government has introduced certain provisions targeting income derived from entities resident in low tax or no tax jurisdictions (see Sec. 12.5.).  As part of such measures, foreign source passive income of capital investments (including capital gains income) received by a non-resident entity will be considered as deemed dividend distributions to its Uruguayan resident individual beneficiaries, if such entity is located in a low tax or no tax jurisdictions. The amount of the income attributed to the individual will be in proportion to their participation in the non-resident entity. Foreign pension and collective investment funds are generally excluded from the rule.

A foreign tax credit is granted in proportion to the foreign source income attributed to the resident.