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Uruguay: New transfer pricing documentation requirements

Uruguay: Transfer pricing documentation requirements

Uruguay’s government in October 2018 issued Decree 353/2018 providing regulatory guidance concerning new transfer pricing documentation requirements.


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In 2017, legislation in Uruguay concerned transfer pricing documentation—including country-by-country (CbC) reporting and Master file requirements. The 2017 law introduced transfer pricing documentation requirements including CbC and Master file requirements that were intended to align Uruguay with current international tax standards and with the OECD base erosion and profit shifting (BEPS) initiative. 

CbC report and Master file

The decree provides regulatory guidance for implementation of the transfer pricing documentation requirements introduced by the 2017 law; sets forth the information to be included in the CbC report and Master file; and establishes which taxpayers are required to provide a CbC report to the Uruguayan tax authorities. 

The CbC report must contain:

  • Information identifying all the entities of the multinational group; the country of tax residence or country of incorporation when it differs from the country of residence; and a description of their business activities
  • The group’s consolidated gross income distinguishing between income from related and non-related entities; pre-tax revenues for the fiscal year; income tax paid during the year; income tax accrued during the year; and information about the share capital, accumulated results, number of employees, and tangible assets

The Master file must include information about the multinational group, including: 

  • Organizational structure
  • Business activities
  • Intangibles
  • Financial activities between related entities

Taxpayers forming part of a “multinational group of large economic dimension,” as defined in the decree, i.e., consolidated total income for the prior year of at least €750 million (approximately U.S. $850 million), must provide the Uruguayan tax authorities with a CbC report except when another group entity has the obligation to file it with the tax authorities of a jurisdiction with which Uruguay has an exchange of tax information in force. In these instances, the local taxpayer must provide the Uruguayan tax authorities, on an annual basis, the name and fiscal residence of the company that will present the CbC report on behalf of the group.

For tax years starting on or after 1 January 2017, taxpayers must provide the Uruguayan tax authorities with the CbC report and Master file within 12 months after the close of their tax year.

Future guidance

Future regulations are expected to clarify certain aspects of the 2017 law. 


For more information, contact a tax professional with KPMG’s Latin America Markets practice or with the KPMG member firm in Colombia:

Alfonso A-Pallete | +1 (305) 913 2789 |

Luis A. Aisenberg | +598 290 24 546 |

Gustavo Melgendler | +598 290 24 546 |

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