Executive summary

On 16 September 2026, the Uruguayan Executive Branch issued a Decree (not yet assigned an official number) introducing targeted amendments to the tax holiday regime applicable to individuals acquiring Uruguayan tax residency from 1 January 2026.

On the same date, the Uruguayan Tax Administration (DGI) issued Resolution No. 2158/026 establishing the procedures, elections and annual compliance requirements applicable to the regime.

The new rules expand the scope of qualifying real estate investments, provide additional flexibility for meeting investment thresholds and establish annual substantiation obligations for taxpayers benefiting from the regime.

New Decree

Following the amendments introduced by Law No. 20,446 and regulated by Decree No. 188/026 (see EY Global Tax Alert, Uruguay amends tax holiday regime, dated 20 August 2026), Uruguay has issued additional regulations concerning the tax holiday regime available to individuals acquiring tax residency from 1 January 2026.

The new provisions mainly focus on the treatment of qualifying real estate investments, the interaction between tax residency and the tax holiday regime, and the procedures required to exercise and maintain the available tax elections.

The chart below highlights key changes made in the new Decree.

Resolution No. 2158/026 complements these amendments by establishing procedures for exercising the available elections, the annual reporting requirements and certain transitional rules for individuals already covered by the previous expatriate regime.

In particular, taxpayers who had opted to be subject to nonresident income tax (NRIT) under the previous regime will generally be deemed to have elected the expanded regime, covering both foreign-source investment income and capital gains. However, they may choose to maintain the election only with respect to foreign-source investment income.

The Resolution also extends until 31 December 2026 the deadline for eligible taxpayers who became Uruguayan tax residents before 2026 to opt into the tax holiday regime.

Resolution No. 2158/026 was published in the Official Gazette on 17 September 2026. Please see the document here (in Spanish). The new Decree has not yet been published in the Official Gazette.

Implications

The new rules increase the flexibility and attractiveness of the tax holiday regime by expanding the range of qualifying investments and allowing a broader group of individuals to benefit from the available tax incentives.