Global Tax Alert (News from Americas Tax Center) | 29 July 2014

Uruguay offers fiscal benefits for restructuring equity participation in international financial institutions

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On 10 July 2014, Uruguay's Ministry of Economy and Finance issued a resolution establishing that the restructuring of equity participations (i.e., shares) in international financial institutions activity will now be promoted under Law No. 16,906 (Investment Promotion and Protection law). Under Law No. 16,906, certain tax exemptions will be available for restructurings of equity participations.

To qualify for the exemptions, the restructuring should be completed through the transfer of equity participation of Uruguayan subsidiaries or branches (i.e., the transfer of shares of a Uruguayan bank) and should:

  • Be authorized by the Uruguayan Central Bank
  • Simplify the group structures arising from the existing shareholding chains
  • Not involve the partial or total substitution of the entity that has effective control of the economic group
  • Comply with the compulsory implementation according to the instructions issued by the Uruguayan Central Bank

For additional information with respect to this Alert, please contact the following:

Ernst & Young Uruguay, Montevideo
  • Martha Roca
    +598 2 902 3147
  • Rodrigo Barrios
    +598 2 902 3147

EYG no. CM4619