Uruguay · Tax regime
Tax Holiday for New Tax Residents
Ley 20.446 (Presupuesto Nacional 2025–2029) substantially rewrote this regime, effective 1 January 2026. The holiday now runs 11 years, the year of arrival plus ten more. The investment gateway was repriced. It moved from roughly USD 590k of real estate to UI 12.5 million (~USD 2m). The old 60-day presence route was removed. Foreign immovable-capital income and capital gains are now taxable for residents outside the holiday.
Eleven years of zero tax on foreign passive income, in a stable, bankable, CRS-compliant jurisdiction with no wealth tax on foreign assets, adds up to the best long-horizon tax holiday in the Americas. It runs longer than Italy's and reads cleaner than Portugal's. Ley 20.446 made the runway longer and the entry price higher at the same time. This is now, explicitly, a regime built for the wealthy.
Qualifying routes
More than 183 days per year. No investment required, but this is now the only presence-based gateway. The previous 60-day route was eliminated.
UI 12,500,000, approximately USD 2 million. That is up from roughly USD 590,000 (UI 3.5m) under the prior Decreto 163/020 regime.
UI 625,000 per year, approximately USD 100,000 annually, into funds financing productive projects, research or applied innovation.
The facts
- Minimum
- $2M
- Total landed cost
- There is no fee for the election itself. The real cost is the qualifying investment plus advisory work. Uruguayan legal and tax structuring for a family typically runs USD 15–40k.
- Route type
- Tax regime, not a visa
- Timeline
- 1–12 months (The election is made once. Obtaining a DGI tax residency certificate takes a few months.)
- Physical presence
- 183+ days if you use the presence gateway. The investment gateways do not require 183 days to qualify for the holiday. Still, you need to be a tax resident for the holiday to mean anything.
- Family
- The election is individual. Each spouse elects separately, and each needs their own qualifying basis
- Permanent residency
- Not applicable. This is a tax regime. Legal residency is a separate track.
- Citizenship
- Not applicable
- Language test
- Not applicable
- Dual citizenship
- Permitted
- Requirements
- Become a Uruguayan tax resident. That means 183+ days in the country, or a centre of economic and vital interests there plus a qualifying investment.Not have been a Uruguayan tax resident in the preceding fiscal years.Not have previously elected the holiday.Make the election with the DGI.
- The regime changed materially on 1 January 2026, and the reform cuts both ways. From that date, foreign immovable-capital income and capital gains on assets producing movable-capital yields become Uruguayan-taxable at 12% for residents who are not inside a holiday. Uruguay is no longer the simple territorial jurisdiction its reputation suggests.
- A new tax-transparency rule attributes income and gains of foreign non-resident entities directly to Uruguayan beneficial owners holding 5% or more, regardless of distribution. Offshore holding structures no longer defer anything. This is the sleeper provision of the reform.
- The real estate gateway more than tripled, from roughly USD 590k to about USD 2m. The 60-day presence route is gone. If you were planning against the old numbers, that plan no longer holds.
- You must not have been a Uruguayan tax resident in the preceding fiscal years, and you must not have used the holiday before. It is available once per lifetime.
- After the holiday ends, you have two choices. One is a rate of roughly 6% for five years, subject to its own investment conditions, such as roughly USD 1m of real estate or USD 100k/year. The other is a fixed annual IRPF amount reported at roughly USD 300,000 (about USD 200,000 with 183+ days presence) for twenty years. Model the exit before you model the entry. For very large portfolios, the fixed-sum option may be the point of the whole exercise.
- The mechanics of the credit for foreign taxes paid were still awaiting implementing regulations as of mid-2026.
- Uruguay has no double-tax treaty with the United States. US citizens get the benefit of the holiday only to the extent that US tax does not simply reclaim it.