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Uruguay: Proposed amendments to budget proposals, including Pillar Two minimum tax

The Executive Branch proposed amendments to the National Budget Bill 2025–2029.

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december 2, 2025

The Executive Branch proposed amendments to the National Budget Bill 2025–2029 (read TaxNewsFlash) affecting the global minimum tax (IMCD) and individual income tax (IRPF).

Changes include applying IMCD from the law’s enactment date, introducing mechanisms to align with existing tax stability rules, and clarifying taxation of foreign capital gains.

The IRPF amendments would allow real or notional profit calculations, permit loss deductions, and contemplate an 8% withholding tax on gains from foreign asset sales when a resident participates in the flow of funds from the corresponding transaction.


For more information, contact a KPMG tax professional in Uruguay:

Luis Aisenberg | luisaisenberg@kpmg.com

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