Uruguay’s 2026 new-resident tax regime: scope and conditions

Uruguay’s new-resident regime can be valuable when it fits the income and the life you plan to have here. Law 20.446, Article 648, now reflected in IRPF Article 24-BIS, gives qualifying new tax residents from 1 January 2026 an election concerning specified foreign capital income.

Start with the income

The 2026 rules extend beyond the older interest-and-dividends summaries. DGI’s explanation identifies foreign movable and immovable capital income and capital gains brought into IRPF. The new-resident election is limited to the income specified in Title 7, Article 6(2), including its exclusions. Salary, active business income and different asset structures need their own classification.

List the actual receipts and holdings before assessing the election: interest, distributions, rents, disposals and the entities through which you own them. An overseas payment alone does not establish the treatment.

Establish residence and the election separately

Becoming a tax resident and qualifying for this election are distinct steps. Under the current Article 5 sexies implementing rules, the alternatives include:

For the presence route, DGI’s residence guidance explains day counting and sporadic absences. Other routes to tax residence, such as family ties or an investment, do not by themselves satisfy the new-resident election’s separate conditions.

The property rules were amended in September 2026. They cover qualifying acquisitions from 1 September 2025 and special fiscal valuation for certain inland urban properties. Use the current implementing text, not an undated dollar equivalent of the UI threshold.

Plan for the full period

The initial election covers the year tax residence changes and the following ten fiscal years, subject to its conditions. Previous residence and use of an earlier regime affect eligibility: the law generally requires no Uruguayan tax residence in the preceding two fiscal years and no use of the earlier regime, with specific transitional provisions. Missing a qualifying year does not restart the original window.

After that period, the law provides further conditional options. Your written assessment should identify the applicable election, evidence, filing steps and the treatment after the initial window.

Permanent legal residence remains a separate immigration procedure. A coordinated plan brings the residence application, tax election, investment decisions and continuing obligations elsewhere into the right sequence. Explore our strategy to see how we bring that work together.

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