On 29 December 2025, Uruguay's Executive Branch issued Decree No. 325/025, setting conditions to exclude from the Qualified Minimum Domestic Top-Up Tax (QDMTT) Free Trade Zone (FTZ) users, forestry entities and multinational groups that have a special agreement in force with the Uruguayan government.

The QDMTT has entered into force in Uruguay for entities with a fiscal year closing as from the enactment date (16 December 2025). (For background, see EY Global Tax Alert, Uruguayan Parliament modifies budget bill to clarify entry into force of the Qualified Minimum Domestic Top-Up Tax, dated 8 December 2025.)

The exclusion would apply under the following conditions:

• Covered entities: The exclusion would apply to FTZ users with agreements approved before the entry into force of the QMDTT, forestry entities with qualified forests planted before the entry into force of the QDMTT, and multinational groups with specific agreements signed with the Uruguayan government before the QDMTT entry-into-force date.
• Exclusion amount: The exclusion form payment may be total or partial and will be assessed as the QMDTT amount that exceeds the amount of the Pillar Two minimum tax that would have been applicable abroad or the QMDTT amount that cannot be credited abroad.
• Reimbursements: If the QMDTT has been paid but the exclusion applies, the Uruguayan Tax Office (Dirección General Impositiva (DGI)) should reimburse the corresponding amount.
• Compliance: To be excluded from payment or obtain the corresponding reimbursement, the constituent entity should demonstrate to the DGI compliance with the conditions in each fiscal year; this is a necessary condition to authorize the DGI to communicate and provide the pertinent documentation to the Base Erosion and Profit Shifting (BEPS) Inclusive Framework.

The Decree has not yet been published in the Official Gazette; it can be accessed here (only in Spanish).