Eligibility & suitability
Who can qualify
- Qualifying individuals becoming tax resident from 1 January 2026 who meet the prior-residence and prior-benefit restrictions.
- Applicants satisfying the regulated investment or annual statutory presence basis.
Restrictions & unsuitable cases
- Applicants seeking relief for local services or all business income without classification.
- Applicants relying only on immigration status or unwilling to maintain annual qualification evidence.
Application process & timeline
This is a tax election, not an immigration permit. The qualifying period can cover the first residence year plus ten following fiscal years; annual supporting evidence is due by 31 March of the following year under the updated resolution.
01Determine the first tax-residence yearBefore the move or before the relevant year closes
Apply the statutory residence tests and review the two preceding fiscal years. Identify any prior article 24 benefit and whether the applicant belongs in a legacy transition rather than the new-arrival regime.
Documents & evidence
- Travel history
- Homes and family facts
- Prior tax-residence records
- Any historic election
- A residence card is not sufficient proof of the tax test.
- Previous use of a regime can restrict eligibility.
02Classify foreign capital and entity incomeBefore choosing the election
Inventory investments and entities, classify income under article 6 and apply article 21 beneficial-owner attribution. Separate local work and business receipts from the income covered by the option.
Documents & evidence
- Portfolio and entity ownership records
- Income statements
- Foreign tax records
- Retained entity profits can be attributed.
- The regime is not an exemption for all foreign bank receipts.
03Establish the investment or presence basisDuring each year for which the condition is required
Confirm the regulated qualifying property or annual fund investment, or meet the article 2(A) more-than-183-day residence basis. Document the relevant indexed-unit amounts and transaction dates.
Documents & evidence
- Qualifying property or fund evidence
- Presence calculation and travel records
- Applicable valuations
- An ordinary fund is not automatically a qualifying productive investment.
- Changing travel plans can undermine a presence-based case.
04File the principal electionUse the currently prescribed DGI procedure
Submit the one-time sworn declaration for the principal option and retain its acceptance record. Resolve any transitional interpretation before relying on it for withholding or a planned disposal.
Documents & evidence
- Prescribed sworn declaration
- Residence and qualification support
- Filing confirmation
- The principal option cannot simply be reversed after filing.
- Historic 2025 marketing does not describe every 2026 case.
05Deliver annual evidence and coordinate withholdingBy 31 March following each relevant year
Supply the required proof of investment or presence even in applicable years with no covered income. Provide the election evidence to paying agents, which verify validity with DGI.
Documents & evidence
- Annual qualification file
- DGI submission confirmation
- Proof supplied to paying agents
- No income does not necessarily remove the annual evidence requirement.
- A bank’s records may need updating independently of the tax return.
06Review the end of the initial period and later optionsBefore the initial benefit period ends; later fixed choices are annual
Compare ordinary tax, the conditional five-year half-rate option and the eligible fixed-amount regime using expected income and family facts. Track the separate investment and payment obligations for the selected route.
Documents & evidence
- Forward income model
- Current investment and presence evidence
- Later election and payment records
- Later relief is conditional and not indefinite.
- Indexed-unit liabilities should not be modelled as fixed US-dollar sums.
Document checklist
Track your preparation in this browser. Final requirements depend on the route and filing authority.
Who the new rules address
Article 24-bis of Title 7 covers individuals becoming Uruguayan tax resident from 1 January 2026. The person must not have been resident during the two immediately preceding fiscal years and must satisfy the restrictions concerning prior use of the earlier regime.
The principal election covers the specified foreign-capital income and gains referenced in article 6. It is not a general exemption for local services, salary, business turnover or every receipt into a foreign account.
Qualifying routes
The law provides an IRNR election for the arrival year and ten subsequent fiscal years. It requires qualifying property investment above UI 12,500,000 or annual capitalisation of specified productive, research or innovation investment funds of at least UI 625,000, subject to implementing rules.
An alternative is to meet the statutory more-than-183-day residence basis in each fiscal year. This can remove the investment requirement for the principal election. UI means indexed units; it is not US dollars, and a fixed dollar equivalent would quickly become misleading.
What happens after the initial period
The law describes a five-year period at half the applicable IRPF rate where the relevant investment conditions are met, or an annual fixed-amount alternative for the covered income. The fixed amounts and reduced variants depend on presence or qualifying productive investment, with specific spousal treatment.
These later alternatives should be modelled with the client’s assets and expected income. They do not justify describing the country as indefinitely tax-free. Existing beneficiaries of the earlier article 24 framework have separate transition provisions.
Election, documents and annual evidence
- Establish the first tax-residence year and prior-residence history.
- Classify each income stream under the current article 6 rules.
- Confirm the qualifying presence or investment basis and supporting evidence.
- Submit the prescribed election; the principal choice is made once and cannot simply be reversed.
- Provide the annual supporting evidence even where no covered income arose.
- Keep paying agents informed and check withholding and foreign-tax-credit treatment.
Deadlines and the practical risk
The updated DGI resolution states a 31 March deadline in the following year for the relevant annual evidence. The procedure was amended on 8 October 2026, so the current form and implementation requirements should be confirmed at filing.
The main pitfalls are using a 2025 summary for a 2026 arrival, treating an immigration card as sufficient residence evidence and failing to maintain the annual qualification. We can help connect the election with the departure plan and the family’s actual travel pattern.
The initial choice and annual proof do different jobs
The principal IRNR option is exercised once by sworn declaration and cannot subsequently be changed. Qualification must nevertheless be evidenced for each relevant year. The updated resolution sets 31 March of the following year for that evidence, including applicable years without the covered foreign-capital income.
A taxpayer should retain the residence calculation, investments or fund capitalisations, and the prior-residence history supporting admission. Separately provide the election evidence to any responsible paying or withholding agent, which must verify validity on DGI’s website before the relevant payment or credit.
Later options have substantial conditions and amounts
After the initial period, one option applies fifty percent of the otherwise applicable IRPF rate for five years if the specified annual fund condition or property investment above UI 6,250,000 is met. This is half a relevant rate, not a five-percent flat tax.
The alternative fixed annual amount is UI 1,875,000, reduced to UI 1,250,000 for the specified presence condition or qualifying direct productive-business investment above UI 45,000,000. Eligible spouses can elect fifteen percent of the relevant fixed amount. These annual choices have the statutory horizon of up to twenty fiscal years following the first election and need detailed modelling.
Legacy beneficiaries need a transition analysis
Article 24 and its historic elections remain relevant for people already in the earlier system. The updated resolution includes transition provisions and a 31 December 2026 election statement, while the consolidated article 24 text contains an earlier date. This draft does not resolve that interaction by assuming the old regime is open to every new arrival.
Establish the year residence arose and any election already made, then obtain a current interpretation of the statute, decree and resolution for that particular case. The appropriate result may differ for an existing beneficiary, a person whose old period has expired and someone genuinely becoming resident for the first time in 2026.
Sources & research notes3 references
Sources supporting this guide. Research draft awaiting editorial review.
