Resolution No. 1517/2026, issued by the Uruguayan Tax Administration (DGI) on 29 June 2026 and published in the Official Gazette on 30 June 2026, establishes the operational and compliance framework for the new Personal Income Tax (PIT) regime applicable to income derived from nonresident entities. The Resolution complements Law No. 20,446 and Decree No. 95/026, which together introduced the substantive rules on foreign-source investment income and capital gains.
The Resolution is available in the Official Gazette (Spanish only).
Foreign tax credits and attribution
The Resolution sets out documentary requirements for claiming foreign tax credits. These cover taxes paid by nonresident entities subject to the attribution regime and non-resident income tax (NRIT) paid on indirect transfers. Excess foreign tax credits may not be carried forward through future withholdings.
For the attribution regime itself, the Resolution introduces ordering rules for attributing income distributed by nonresident entities. Income already effectively taxed under Corporate Income Tax is excluded from attribution.
Withholding obligations and ownership chains
Where ownership structures involve resident entities, nonresident entities or mixed chains, the Resolution identifies which entity bears responsibility for withholding. It also clarifies when a resident entity is treated as a custodian of foreign assets, regulates the election to treat withholdings as final tax, and introduces verification requirements for taxpayers claiming the expatriate regime.
Semiannual advance payments are required at a 12% rate for foreign-source immovable income, movable income and capital gains in cases where withholding does not apply.
Capital gains, market values and losses
The Resolution provides rules for substantiating the tax basis of investments. It recognises Bloomberg as the reference source for quoted market values. Certain losses may be offset against other foreign-source capital income.
Simplified regime
The simplified regime, structured as a lump sum of approximately US$300,000, is elected by filing the first tax return under that basis. Once elected, it may remain in force for up to 20 consecutive years, with returns filed accordingly throughout that period.
Transitional provisions
Certain withholding obligations and advance payments relating to the initial implementation period are postponed until October 2026. Taxpayers with relevant ownership structures, cross-border investment income or withholding agent status should review their documentation, processes and elections in light of the Resolution's requirements before that date.