Guest post from Bergstein Law of Uruguay

On June 28, 2019 the European Union and the MERCOSUR group − comprised of Argentina, Brazil, Paraguay and Uruguay − reached a mutual understanding  over a trade agreement. Both sides have been negotiating such an agreement for 20 years. European Commission President Jean-Claude Juncker calls this the largest trade agreement the European Union has ever concluded.
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Guest post from our friends at Bergstein Abogados

Uruguay requires online companies incorporated abroad, with no presence in Uruguay, to pay taxes in Uruguay whenever their clients are located within Uruguayan territory. Online services providers (such as Netflix and Spotify) are subject to VAT at the rate of 22 percent, plus Non-Residents Income Tax (so-called IRNR) at the rate of 12 percent, both assessed over the sales price. Online services intermediaries (such as Airbnb) are subject to the same taxes, except that IRNR is assessed only over 50 percent of their sales where one of the parties of the ultimate transaction (the supplier or end-user) is based abroad.

In May this year, Uruguay’s Executive Branch issued a regulatory decree, summarized below, clarifying aspects of the tax law; and a few days ago, the Tax Office issued a special resolution spelling out certain implementation details.
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The following is a guest post from Bergstein Abogados, Montevideo, Uruguay

Over the last few years, Uruguay has fully aligned with OECD standards. For example, Uruguay has entered into more than 10 tax information exchange agreements and more than 15 double taxation agreements. Uruguay became a member of the Committee on Fiscal Affairs, signed the Convention on Mutual Administrative Assistance in Tax Matters. Uruguay, and also agreed to start the automatic exchange of information in September 2018.

In this context, on December 29, 2016, Uruguayan Parliament passed the Tax Transparency Act.
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Guest Post: Jonás Bergstein and Guzmán Ramírez are partners in Bergstein Abogados, based in Montevideo, Uruguay

Recent voluntary-disclosure programs in Latin America (most notably in Argentina, Brazil, Chile, and Colombia) have cast light on Uruguay as a suitable jurisdiction for Latin America business persons seeking to establish tax residence.

Uruguay’s historical political stability, democratic traditions, low corruption levels, and independent judiciary all contribute to this increased interest. Also contributing to the boom in interest is Uruguay’s attractive tax system.

This note briefly discusses the characteristics Uruguay offers for personal income tax planning purposes, with a special emphasis on the standards which trigger tax residence in Uruguay.
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The following is a guest post from Bergstein Law in Uruguay

Free Trade Zones (“FTZs”) play a key role in the attraction of foreign investment to Uruguay.  It is estimated that over last decade total accumulated investments in the FTZs amounted to more than USD$5.7 billion, thus becoming one of the main drivers of the Uruguayan economy.

All sorts of activities can be conducted in the FTZs: manufacturing, trade, warehouse, logistics, and services and across all industry sectors of multinationals, including but not limited to soft beverages (PepsiCo), pulp-mills (UPM), asset-managers (Julius Baer), advisory services (the big four included), printing manufacturers (Lexmark), toy industry (Sony) and pharmaceuticals.

Free Trade Zones are specifically delimited areas of the Uruguayan territory in which operations of all types can be conducted at zero tax. FTZsare governed by a legal regime which has been in place for more than 25 years and serve as distribution, trading, logistics, financial and services hub in the region. 
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