background image
5.2. Treatment of Foreign Profits / Losses

Uruguay has a territorial tax system. Only domestic-sourced income and capital gains are taxed. Foreign-source income is not taxable even if remitted to Uruguay.

Effective 1 January 2023, as an exception to the territorial tax system, Uruguay introduced new income source rules for passive income from foreign sources received by entities that are members of MNE groups (see Sec. 12.5.).