Free Trade Zones in Uruguay in 2026: What Has Changed and What to Review

The core of Uruguay’s “ Regime ” for free trade zones has remained unchanged since 1987: exemption from national taxes and a government guarantee of those benefits. What has changed, however, is what the “ Regime ” requires in return and how these benefits are treated under international tax rules. For a company planning regional expansion, these changes determine which structure to adopt. If you need the basics first, we explain them in our frequently asked questions about free trade zones.

Three milestones of the Regime

1987 · Law 15,921. This law establishes an exemption from all national taxes—whether currently in effect or to be enacted in the future—for activities in the zone. The government guarantees these benefits for the duration of the contract.

2017 · Law 19,566. The user agreement now includes the business plan. Services are made available to IRAE taxpayers in the non-tax-exempt territory, and rules are established for intellectual property income.

2026 · Domestic Minimum Complementary Tax (IMCD). Multinational groups with consolidated revenues exceeding EUR 750 million are subject to a minimum tax rate, in line with the OECD’s global minimum tax.

What the " Regime" Requires Today: Substance, Not Just a Address

Under Law 19,566, the operator and the government evaluate the project before approving it. The company submits its investment and business plan, and the contract is tied to that activity. In practice, “substance” means four things:

1. Local workforce: As a general rule, at least 50% must be Uruguayan for service-related activities and 75% for logistics and industrial activities.
2. Physical space appropriate for the activity: offices, warehouses, or the facility where the Operation takes place.
3. Expenditures and Decisions in Uruguay: Operations are managed locally.
4. Consistency with the business plan: the actual “ Operation ” matches what was approved in the contract.

An organization without equipment or a real Operation doesn't fit into today's Regime . This benefits companies that set up specific regional operations.

What Does the IMCD Mean for a Multinational Company?

The IMCD applies only to groups with consolidated revenues exceeding EUR 750 million. For those groups, the tax exemption is no longer the sole factor in the decision: the group pays a minimum amount of tax in Uruguay rather than in the country where its parent company is located. For all other companies, the tax exemption remains unchanged.

For this reason, in large groups, the choice of a free trade zone is increasingly based on operational factors: stability, talent, infrastructure, the free flow of capital, and access to the region.

Four Questions to Discuss with Your Tax Advisor

1. Does the group have consolidated revenue exceeding EUR 750 million?
2. What is the main market for " Operation": abroad, Uruguay, or both?
3. Which positions will be filled, and how many people will be hired?
4. Does the " Operation " generate its own intellectual property?

At Zonamerica, we work with both regimes—the free trade zone and the Investment Promotion Act—so that each project is evaluated within the framework that corresponds to its activity.