Relocating to Uruguay as an entrepreneur or investor: legal, tax and family plan

Moving to Uruguay with your family and your wealth is not one procedure but a chain of them. Immigration status, tax residency, exit from the home country, the business, banking and the family all depend on each other, and the order in which they happen changes the tax cost. This guide explains how a business owner or investor can plan a relocation to Uruguay step by step, under the rules in force after Law 20.446.

Main guide: how to obtain legal residency in Uruguay, covering the types of residency, the requirements and the procedure before the immigration authorities.

Why relocation needs a sequence

Some decisions only work if they are made before a certain date. Three questions drive the whole process:

1. From when will you be tax resident in Uruguay? This sets the first tax year in which Uruguayan IRPF applies and when any special regime starts to run.
2. When do you stop being resident in your home country? Each country has its own exit rules, and there may be a period in which both treat you as resident.
3. What happens to the company and the assets? Selling, restructuring or distributing before or after the move is taxed differently.

Step 1: legal residency

Legal residency is the immigration permit to live in the country, and it is separate from tax residency: you can have one without the other. The most common routes for business owners and investors are:

• Temporary or permanent residency, depending on your profile and the means of support you can prove. See how to obtain legal residency in Uruguay.
• Mercosur residency for nationals of the bloc and associated countries, processed since 2023 by the National Migration Directorate (DNM), as is residency based on family ties.
• Investment-linked residency, when a project or a property purchase is at the centre of the move. Details in Uruguay residency by investment.

Step 2: when you become tax resident

The IRPF law (article 2 of Title 7 of the 2023 Consolidated Text) provides that an individual is tax resident in Uruguay if either of the following applies:

• Presence of more than 183 days in Uruguay during the calendar year. Sporadic absences are counted under the conditions set by the regulations, unless the person proves tax residency in another country.
• The main core or base of their activities or of their economic or vital interests is in Uruguay. Vital interests are presumed to be in the country, unless proven otherwise, when the spouse and dependent minor children habitually live there.

Decree 148/007 (article 5 bis) specifies when the base of economic interests is considered to be in Uruguay through investment:

Investment ground	Requirement
Real estate	More than UI 15,000,000, at updated tax cost.
Real estate plus physical presence	More than UI 3,500,000 in property acquired since 1 July 2020 and at least 60 days of actual physical presence in the calendar year.
Company with a project of national interest	More than UI 45,000,000, directly or indirectly, in a company with projects declared of national interest (Law 16.906).
Company creating jobs	More than UI 15,000,000 since 1 July 2020 and at least 15 new direct, full-time jobs in the calendar year.

Tax residency is evidenced before the DGI, which issues the tax residence certificate used with the home country or with banks. The grounds are covered in detail in how to obtain tax residency in Uruguay.

Step 3: the new-resident regime from 2026

Uruguay levies IRPF on Uruguayan-source income and, since 2011, on certain foreign capital income of its residents. Law 20.446, in force since 1 January 2026, widened that scope: according to the DGI, foreign income from movable and immovable capital and foreign capital gains on movable and immovable assets are now taxed. Foreign-source employment income remains outside the tax.

For anyone relocating, the key piece is the new impatriate regime (article 24-BIS of Title 7, added by article 648 of Law 20.446 and regulated by Decree 188/026):

Item	Regime for those becoming tax resident from 1/1/2026
Option	Pay IRNR (instead of IRPF) on foreign capital income in the year of the change of residency and the following 10 years. It can be exercised only once.
Access condition	One of: a) spending more than 183 days in the calendar year, every year; b) investing more than UI 12,500,000 in urban real estate acquired from 1/1/2026; c) contributing at least UI 625,000 a year to investment funds financing productive projects, research or innovation.
Prior requirement	Not having been tax resident in the two previous tax years and not having used the previous regime.
After the 11 years	Opt for IRPF at 50% of the applicable rate for 5 years (while keeping real estate of more than UI 6,250,000 or the fund investment), or pay a fixed annual amount of UI 1,875,000 on all such income, reduced to UI 1,250,000 in years with more than 183 days of presence or with a direct investment of more than UI 45,000,000 in a company.
Spouse	May join the fixed-amount option and pays 15% of that amount.

Two practical details from the decree: property located in departments with no coastline on the Río de la Plata or the Atlantic Ocean counts at its tax cost increased by 50%, and the properties used for the regime cannot be the same ones used to qualify for tax residency by investment. A person who fails the conditions in a given year can rejoin when they meet them again, but the term keeps running.

Those who exercised the previous regime’s option by 31 December 2025 (IRNR or IRPF at 7%) keep it on its original terms. For how each variant works, see the Uruguay tax holiday.

Step 4: leaving your home country

Uruguay does not decide when you stop being resident elsewhere: each jurisdiction has its own criteria and, often, exit obligations. Points to review with an adviser in your home country:

• Loss of residency: whether it requires formal notice, a certificate from the new country or a minimum period abroad.
• Exit taxes: some countries tax unrealised gains on shares or other assets when residency ends.
• Dual residency: if both countries treat you as resident, a double tax treaty may resolve it through tie-breaker rules; without a treaty the risk is higher.
• Liquidity events: selling the company, collecting accumulated dividends or selling a property may be taxed differently before or after the change of residency, now that Uruguay also taxes certain foreign capital gains.

Step 5: moving the business or keeping it abroad

Under Uruguayan law, a company is resident if it was incorporated under Uruguayan law, and a foreign entity becomes resident when it moves its domicile to the country and completes the formal procedures (article 3 of Title 4). That opens three routes:

• Keeping the company abroad: possible, but if the owner runs it from Uruguay, the home country may question where its place of effective management is, and a permanent establishment may arise in Uruguay. Dividends become foreign capital income of the new resident.
• Setting up an entity in Uruguay: a local company or a branch of the foreign company, with real accounts, staff and substance. See setting up a foreign company in Uruguay.
• Moving the company’s domicile to Uruguay, where the home country’s law allows it, so it becomes resident without being dissolved.

Substance matters on both sides. For tax years beginning on or after 1 January 2023 (Law 20.095), certain foreign passive income of entities in multinational groups is subject to IRAE unless the entity has adequate economic substance in the country: appropriate staff and premises, strategic decisions taken in Uruguay and reasonable costs.

Step 6: banking and source of funds

Opening accounts is often the bottleneck. Banks apply due diligence and ask for identification, residency, activity and, above all, the source of funds. For a business owner, that means having financial statements, dividend resolutions, sale contracts and home-country tax returns in order.

In addition, Uruguayan financial institutions report non-resident accounts to the DGI under automatic exchange of information (CRS), and Uruguayan companies must declare their beneficial owners to the BCU (Law 19.484). See how to open a bank account in Uruguay.

Step 7: the family

The family is part of the tax analysis. If the spouse and dependent minor children habitually live in Uruguay, vital interests are presumed to be in the country even if the business owner spends fewer than 183 days there; if the family stays behind, the home country may continue to treat them as resident.

• Residency for spouse and children: they can apply for residency based on family ties, handled by the DNM since 2023. See Uruguay family residency.
• Spouse’s treatment: under the fixed amount available after the impatriate regime, the spouse pays 15% of the applicable amount.

Timeline and checklist

Stage	Tasks
Before moving	Tax review in both countries; decide what happens to the company; plan sales and distributions; legalised family documents; evidence of source of funds.
Arrival	Start legal residency for the whole family; record the entry date; apply for the identity card; open accounts.
First year	Confirm the tax residency ground (days, vital interests or investment); assess and exercise the impatriate regime option; set up the chosen business structure.
Following years	Evidence the conditions every year (presence or investment); request the tax residence certificate when needed; review the substance of the entities.

Common mistakes

• Confusing legal and tax residency: holding a Uruguayan identity card does not mean paying tax in Uruguay, nor ceasing to pay it at home.
• Assuming the tax holiday is automatic: since 2026 it requires more than 183 days a year or an investment that is maintained.
• Selling assets or collecting dividends without planning the date: the same event may be taxed in one country, the other or both.

FAQ

Relocating to Uruguay with GlobalTax

At GlobalTax we handle legal residency for the whole family, the tax residency and impatriate regime analysis, and the business structure in Uruguay, working alongside advisers in the home country. Learn more on our page about legal residency in Uruguay.