Minimum Complementary Domestic Tax in Uruguay: Key points of Decree 325/025

The Executive Branch of Uruguay published Decree 325/025 , regulating the Minimum Complementary Domestic Tax (IMCD) and incorporating key definitions for its application within the Uruguayan tax system.

The regulation provides legal and tax certainty regarding the incorporation of this new tax, regulating its interaction with the tax stability clauses already in force in the country.

What is the Minimum Complementary Domestic Tax in Uruguay?

The Minimum Complementary Domestic Tax in Uruguay establishes a tax floor of 15% on the income of entities that are part of multinational groups whose annual income exceeds the threshold defined by international regulations.

The decree regulates article 666 of Law No. 20,446 , resolving the technical challenge of reconciling the IMCD with the commitments assumed by the State under special investment promotion regimes.

IMCD Dispensing and Reimbursement Mechanism

One of the central aspects of the regulation of the Minimum Complementary Domestic Tax in Uruguay is the introduction of a dispensation mechanism , designed to avoid double taxation or the breaking of stability contracts.

Scope of the dispensation

Entities covered by tax stability clauses may be exempt from paying the IMCD, either totally or partially.

Technical application condition

The exemption applies when the tax determined in Uruguay exceeds the tax that would have been calculated abroad in the absence of the local IMCD, in accordance with the Global Anti-Erosion Rules (GloBE) of the Inclusive Framework.

Amount of benefit

The benefit is equivalent to:

• The portion of the tax that is not creditable abroad, or

• The difference between local tax and tax determined abroad.

  
  

Refund policy

When the taxpayer has paid the IMCD despite being entitled to the exemption, the General Directorate of Taxation (DGI) must reimburse the amount paid in excess .

Specific areas of application of tax stability

The decree explicitly identifies the scenarios in which stability clauses prevail over the Minimum Complementary Domestic Tax in Uruguay :

Free Trade Zones

Users whose contracts were signed and authorized before the validity of the IMCD , in accordance with articles 19, 20 and 25 of Law No. 15,921.

Forestry sector

Taxpayers with forests planted prior to the entry into force of the tax, covered by article 43 of Law No. 15,939.

Specific agreements

Specific agreements signed between the Uruguayan Government and multinational groups prior to the validity of the IMCD.

Administrative procedure and international transparency

Access to the exemption or refund is not automatic. The decree requires a formal procedure before the tax authority.

Procedure before the DGI

The taxpayer must initiate an administrative file with the DGI, proving compliance with the conditions in each fiscal year.

BEPS Transparency

As a necessary condition, the multinational group must authorize the DGI to share information on the waiver or refund with the BEPS (Base Erosion and Profit Shifting) Inclusive Framework , reinforcing international transparency commitments.

Source : Presidency of the Republic

Brinta and the IMCD in Uruguay

The application of the IMCD in Uruguay requires coordination between local rules, GloBE standards and tax stability commitments .

Brinta helps multinational groups centralize tax information and manage IMCD compliance with greater control and traceability .

Talk to our team and prepare your operation for the IMCD in Uruguay.