Tax residence and the 2026 foreign-income rules

More than 183 days is one residence ground

Presence exceeding 183 days in a calendar year establishes residence. Entry and exit days count, transit between third countries does not, and absences of at most 30 consecutive days count unless foreign tax residence is certified. A foreign certificate does not negate sufficient actual Uruguayan presence.

Other residence grounds operate independently

Vital interests, the main activity base or economic interests can establish residence without the day test. The rebuttable family presumption concerns a habitually resident spouse who is not legally separated and dependent minor children, or that spouse if there are no children. The activity test compares gross income country by country, excluding exclusively passive capital income; specified investment presumptions have separate conditions.

Residents and nonresidents have distinct taxes

Ordinary residents generally fall under IRPF; nonresidents without a Uruguayan permanent establishment generally fall under IRNR, while establishment cases require the IRAE rules. Both IRPF and IRNR cover domestic-source income, with statutory extensions: for example, IRPF can treat employment performed abroad for specified Uruguayan taxpayers as domestic source, while IRNR includes specified overseas technical services connected with a payer's IRAE-taxable income.

Foreign capital coverage expanded in 2026

DGI confirms that from 1 January 2026 IRPF covers foreign movable and immovable capital returns and gains. Statutory exclusions and attribution rules still apply; neither blanket territorial exemption nor taxation of every kind of worldwide income accurately describes this baseline.

Effective from 2026-01-01

New-resident elections are cohort-specific

The legacy Article 24 election could be made only through 31 December 2025; existing elected periods require separate assessment. Article 24-bis offers qualifying 2026-onward arrivals an IRNR election for covered foreign capital income for arrival year plus ten years, with investment conditions or the statutory presence test each year, preceding two-year nonresidence and no earlier Article 24 use, subject to transition provisions.

Effective from 2026-01-01

Relief is conditional

Foreign tax on covered Article 6(2) income can be credited up to the corresponding IRPF liability, subject to regulations. DGI separately lists treaties, their tax-effective dates and applicable multilateral modifications; treaty coverage is not a blanket exemption.