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Volume 59, Number 13 September 27, 2010

(C) Tax Analysts 2010. All rights reserved. Tax Analysts does not claim copyright in any public domain or third party content.
Budget Would Alter Taxation of
Foreign Companies

by Guzmn Ramrez

Reprinted from Tax Notes Intl, September 27, 2010, p. 1023


Reprinted from Tax Notes Intl, September 27, 2010, p. 1023

COUNTRY

(C) Tax Analysts 2010. All rights reserved. Tax Analysts does not claim copyright in any public domain or third party content.
DIGEST
Budget Would Alter Taxation of importers equivalent to 2 percent of the value of im-
ported merchandise. The current administration has
Foreign Companies now decided that importers will continue to pay the
The Uruguayan government on August 31 presented tax.
the parliament with its budget proposal for the next Persons engaged as employees of companies located
five years. in Uruguay would pay personal income tax (IRPF) on
Last-minute changes to the bill provide for signifi- income generated in Uruguayan territory as well as
cant tax changes, including changes to the taxation of income generated abroad. Currently a manager of a
foreign companies established in Uruguay. Parliament Uruguayan company who constantly travels to other
now has until November 29 to discuss and approve the countries because of his regional coordination work
bill. does not pay tax on the portion of his salary generated
Under the proposal, foreign companies established abroad. Upon parliamentary approval of the budget,
in Uruguay to provide services of any nature would in those regional managers will have to pay tax on their
all cases pay a 25 percent income tax (IRAE), even if total salaries.
personnel are contracted abroad. They currently pay Technical personnel (for example, software experts)
tax only when they hire personnel in Uruguayan terri- performing services for a company located in Uruguay
tory. would also have to pay IRPF on all of their income,
Foreign companies established in Uruguay to pro- including income generated abroad. Currently they pay
vide services or undertake construction work would tax only on the portion of their services rendered in
not be taxed on income not directly linked to their ac- Uruguayan territory.
tivities. Currently all their income is taxed. Under the budget proposal, if the director of a com-
Maritime and air navigation companies are exempt pany located in Uruguay dies, his heirs would have to
from IRAE on all income. Upon approval of the new pay any tax owed by the company, in addition to his
national budget, they will only be exempt from income personal debts.
linked to their transport activity.
The previous administration had planned to repeal Guzmn Ramrez, associate, Ferrere Attorneys at Law,
as of January 2011 a tax (consular tax) imposed on Montevideo

TAX NOTES INTERNATIONAL SEPTEMBER 27, 2010 1

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