Global Tax Alert | 10 July 2013

Uruguay proposes repeal of capital gains tax exemption on transfer of bearer shares

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On 30 June 2013, the Uruguayan Executive Power sent the 2012 budget project bill for the Parliament's consideration. Article 309 of this bill eliminates the capital gains tax exemption on the transfer of bearer shares issued by Uruguayan companies. At present, this exemption applies only if the transfer is performed by non-residents or Uruguayan tax resident individuals.

Should Article 309 be approved, the transfer of bearer shares by nonresidents or Uruguayan tax resident individuals will be subject to capital gains tax as follows: 12% rate applicable on a deemed profit of 20% of their sale price (which should correspond to the fair market value).

The proposed elimination of this exemption is not surprising, considering the creation in 2012 of the bearer shares owners' registry managed by the Central Bank of Uruguay.

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

Ernst & Young (Uruguay), Montevideo
  • Martha Roca
    +598 2902 3147
  • Rodrigo Barrios
    +598 2902 3147
Ernst & Young LLP, Latin American Business Center, New York
  • Pablo Wejcman
    +1 212 773 5129

EYG no. CM3627