Uruguay as a regional hub for holding structures: why will it remain relevant in 2026?
- Mar 26
- 1 min read
Uruguay is not a tax haven in the classic sense of the term. It combines stability, legal sophistication, and a territorially defined tax framework that makes it competitive compared to other regional options.
The advantages that position Uruguay
Legal and institutional stability: one of the most stable democracies in the region
Principle of territoriality: foreign source income is not subject to IRAE tax
Network of double taxation agreements with countries relevant to the region
A solid and regulated banking system with access to international financial services
Not included on OECD or EU blacklists or greylists
The combination of territoriality, stability, and international recognition makes Uruguay especially useful as a bridge between Latin American subsidiaries and shareholders based in Europe, the US, or Asia.
Changes from 2026 onwards: what you need to know
The circumstances under which dividends distributed to non-resident shareholders are taxed (IRNR) have been broadened. Specifically, dividends will be taxed if they are subject to taxation in the non-resident beneficiary's jurisdiction and that jurisdiction offers a tax credit for the tax paid in Uruguay. This means that some dividends that were previously exempt from IRNR withholding may now be subject to this 7% withholding tax.
Is Uruguay still competitive?
Yes, for structures where the shareholders are not residents of Uruguay, the principle of territoriality regarding the company's income is maintained.
Uruguay remains a preferred jurisdiction for regional holding companies in 2026, but the design must incorporate the new rules. Planning that fails to update the tax analysis can lead to unforeseen exposure.
