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08 December 2025

Uruguayan Parliament modifies budget bill to clarify entry into force of the Qualified Minimum Domestic Top-Up Tax

  • On 3 December 2025, the Uruguayan Senate approved modifications to the budget bill clarifying that the Qualified Minimum Domestic Top-Up Tax (QMDTT) will take effect on the law's enactment date, rather than on the previous date sanctioned by Parliament.
  • The QMDTT is expected to apply to fiscal years ending on or after 31 December 2025, aligning with the Executive Branch's intentions for implementation.
  • The bill must now return to the House of Representatives for a second constitutional approval, before the Executive Branch can enact the law and publish it in the Official Gazette.
  • Affected entities should prepare for the implications of the QMDTT on their tax planning and compliance, as the new tax will affect fiscal reporting and obligations starting from the end of 2025.
 

On 3 December 2025, the Senate approved the budget bill clarifying that the Qualified Minimum Domestic Top-Up Tax (QMDTT) will enter into force as of the enactment date of the law (previous version considered the law sanction date by Parliament). Therefore, it should be expected that the QDMTT will apply for fiscal years ended on 31 December 2025 and onward, which has been the Executive Branch's intention.

Under Uruguay's legislative procedure, the bill must now return to the House of Representatives for the second approval required by the Constitution. Once this second approval is granted, the Executive Branch must enact the law, after which it will be published in the Official Gazette.

Other changes to the Budget Bill will be addressed in a separate Alert.

The new version of the Budget Bill was published on 3 December 2025 and can be accessed here (in Spanish only). More details will be provided as new developments arise. For prior coverage, see EY Global Tax Alert, Uruguay proposes amendments to National Budget Bill 2025—2029, dated 7 October 2025.

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Contact Information

For additional information concerning this Alert, please contact:

EY Uruguay, Montevideo

Published by NTD’s Tax Technical Knowledge Services group; Carolyn Wright, legal editor

Document ID: 2025-2453

 

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