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Uruguay: Budget 2025-2029 enacted, including Pillar Two minimum tax

Qualified domestic minimum top-up tax applies to fiscal years ending on or after December 16, 2025.

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February 10, 2026

The Executive Branch enacted the National Budget Law for 2025–2029, which includes a qualified domestic minimum top-up tax (QMDTT).

Most provisions of the budget became effective January 1, 2026, however the QMDTT applies to fiscal years ending on or after December 16, 2025.

In addition, the Executive Branch on December 29, 2025, issued Decree No. 325/025, exempting from QDMTT certain entities subject to tax stability clauses (e.g., free zone companies, forestry entities, and multinational enterprise (MNE) groups with pre-existing agreements with the government). For cases in which QDMTT has already been paid, eligible entities may receive refunds by filing a request with the tax authority.


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

Luis Aisenberg | luisaisenberg@kpmg.com

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