Uruguay Tax Residency: What the DGI Says and What to Discuss With a Professional

The four DGI criteria for tax residency, how to request the certificate and what the regime for new residents establishes from 2026. General information.

Uruguay Tax Residency: What the DGI Says and What to Discuss With a Professional

This article is for people who live in Uruguay or plan to, particularly on the east coast, and need to understand how the DGI (Uruguay’s tax authority, Dirección General Impositiva) defines tax residency, what proof it requires to issue the certificate, and what changed in 2026 for those settling in the country for the first time. It addresses the most frequent searches on requirements, the “tax holiday” and the tax residency certificate.

This is general information, drawn only from official sources, and does not constitute tax or legal advice. Tax residency has different effects depending on each person’s situation and country of origin; the decision should be made with an accountant or a tax lawyer.

Notice

This article describes public rules and guidance as of the date of consultation (October 8, 2026). The rules were amended by Law 20.446 and its implementing regulations continue to be published; amounts and conditions may change. Before moving, buying property or choosing a regime, a qualified professional should be consulted.

When a person is a tax resident: the four DGI criteria

The DGI issues the tax residency certificate when it finds that one of the grounds set out in the regulations is met. For individuals, its certificate page and the application procedure list four:

  • Presence: more than 183 days in the country in the calendar year, shown by the certificate of migration records from the Dirección Nacional de Migración (National Directorate of Migration).
  • Main center or base of activities: income generated in Uruguay exceeds that from any other country. For income other than salaried work or pensions, the DGI requires an accountant’s certificate detailing income by country and a sworn statement.
  • Economic interests: a real estate investment above 15,000,000 indexed units (UI), or above 3,500,000 UI made since July 1, 2020 together with more than 60 days of physical presence in the year. In companies, an investment above 45,000,000 UI in a promoted project, or above 15,000,000 UI since July 1, 2020 if it creates at least 15 jobs. This ground is verified as of December 31, so the certificate is requested for the year after it ends.
  • Vital interests: the spouse and minor children reside in the country. This is proven with the residency certificates of those family members and the marriage or birth certificates, or with other documentation from the period, such as health coverage or school enrollment.

The value of the UI is updated periodically, so the dollar equivalent of the thresholds must be calculated as of the date of the transaction.

The tax residency certificate

According to the DGI, the procedure can be started online, with an Identidad Digital user account, from “Otros Servicios” (Other Services), “Iniciar expediente” (Start a case file), “Certificado de Residencia Fiscal” (Tax Residency Certificate), or in person at the DGI headquarters in Montevideo or at any office in the interior of the country. It requires completing form 5202, attaching supporting documentation and establishing an electronic domicile (DOMEL). Once the DGI verifies the ground, it sends the digitally signed certificate to the email address of the registered domicile. The certificate covers the full calendar year. For the grounds of effective presence or vital interests, it can be requested as soon as they are met; for those of main center of activities or economic interests, for the year after it ends.

The pages consulted do not state the cost of the procedure or the issuance time, two items that should be confirmed with the DGI.

The regime for new residents (“tax holiday”) from 2026

Article 24-BIS of Title 7 of the 2023 Consolidated Text (Texto Ordenado 2023), added by article 648 of Law 20.446 (National Budget, December 16, 2025), regulates an option for individuals who acquire tax residency from January 1, 2026. According to the text published by IMPO:

  • The option can be exercised only once and allows the person to pay Non-Resident Income Tax (IRNR, Impuesto a la Renta de los No Residentes) in the fiscal year of the change of residency and the ten following years, only on the income under item 2) of article 6.
  • To qualify, the person must invest in real estate more than 12,500,000 UI, as set by the regulations, or capitalize investment funds for productive or research and innovation projects for at least 625,000 UI per year. Those who meet the case in subparagraph A) of article 2 in each fiscal year do not need to prove that investment.
  • The person must not have been a tax resident in the two prior fiscal years or have applied the regime of the preceding article, with some exceptions.

Once that period ends, the rule allows two paths. The first is to pay Personal Income Tax (IRPF, Impuesto a la Renta de las Personas Físicas) at 50% of the applicable rate for five fiscal years, once only, on the condition of capitalizing funds each year or investing in real estate more than 6,250,000 UI. The second is to pay a fixed annual amount of IRPF on that income: 1,875,000 UI, or 1,250,000 UI in the years in which the case in subparagraph A) of article 2 is met. Spouses may opt in by paying 15% of those amounts. The annual options can be exercised for up to twenty fiscal years after the first.

The rule refers to the regulations for the terms and conditions. Decree 188/026, enacted on August 10, 2026 and published on August 19, amends Decree 148/007, which regulates this regime. The DGI also maintains a guide to the option dated October 15, 2025, which predates the reform and describes the scheme for those who acquired tax residency from January 1, 2020: IRNR during the year of the change and the ten following years, or IRPF at 7% with no time limit, using form 0306.

What to discuss with an accountant or lawyer

  • The date from which residency is counted and which of the four criteria will be invoked.
  • The count of days of presence and the migration documentation that supports it.
  • Whether the real estate or fund investment meets the requirements set by Decree 188/026 and how it is valued in UI.
  • Whether exercising the option is advisable, given that it can be exercised only once, and what the consequences are after the ten years.
  • The tax situation in the country of origin and whether a double taxation treaty exists.

Disclaimer

This article is for information only and does not constitute legal, tax or accounting advice. Modo Punta accepts no liability for decisions made on the basis of its content. For greater certainty about your particular situation, consult an accountant: the Modo Punta Guide lists Estudio Gadda & Magnani, accountants and advisors in Uruguay.

How this article was prepared

We consulted the DGI site on gub.uy (tax residency certificate, application procedure and guide to the option for new residents) and the IMPO pages on Law 20.446, article 24-BIS of Title 7 and Decree 188/026, all on October 8, 2026. No private sources were used for the requirements. The full text of some implementing articles could not be read, and this is noted as pending verification.

Sources consulted

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