On 30 September 2025, the Ministry of Economy and Finance proposed amendments to the National Budget Bill for the 2025–2029 period before the Chamber of Deputies.

The proposed amendments establish that the Domestic Complementary Minimum Tax (IMCD) will apply to fiscal years closing as from the enactment of the law, rather than after 1 January 2026. In addition, a new article empowers the Executive Branch to regulate mechanisms to align the IMCD with tax-stability regimes, such as Free Trade Zones. Entities will be able to demonstrate, through a standardized procedure, that they fall outside the scope of the IMCD if the multinational group does not apply the Global Anti-Base Erosion (GloBE) Rules or does not have a regime that allows it to credit the Uruguayan tax.

Amendments are also proposed for the Individual Income Tax (IRPF). Although modifications to the rules for taxing foreign capital gains will be specified, they are not yet available. Resident individuals may choose between a real or notional regime to calculate capital gains. Taxable gain for listed financial assets will be the equal to the difference between the assets' fiscal value on the date of transfer and their fiscal value on 31 December 2025. If an asset abroad is being sold or transferred at a lower price than its purchase price and generates a loss, the loss may be deducted from the gains derived from yields of capital. A resident taxpayer who participates in the transaction will withhold tax at a rate of 8%, making the withholding definitive.

More details will be provided as new developments arise. For prior coverage, see EY Global Tax Alert, Uruguay presents bill proposal for the National Budget 2025-2029, dated 9 September 2025.