Uruguay regulates new Tax Holiday regime for 2026 impatriates

The Uruguayan Executive Branch has regulated the new impatriate tax regime, commonly known as the ‘Tax Holiday,’ which will apply to those acquiring tax residency in Uruguay starting January 1, 2026.

Under the new decree, which modifies Decree 148/007, eligible individuals may opt to pay the Non-Resident Income Tax (IRNR) on certain foreign income during the year of residency change and for the following ten fiscal years. To maintain this benefit, residents must meet one of three annual conditions.

One option is to remain in Uruguay for more than 183 days. Alternatively, individuals may qualify by investing in urban real estate valued at more than 12,500,000 indexed units (UI). These investments must be made in properties acquired from January 1, 2026, and cannot be the same properties used to establish tax residency through real estate criteria. The decree clarifies that tax residency and the tax benefit are distinct; an individual must first establish residency through existing legal causes before exercising the one-time tax option.