A tax connection with Uruguay that is not defined by the number of days of stay alone.
Tax residency defines a person's tax connection with Uruguay, and it is not determined solely by the number of days spent in the country.
In an increasingly globalized world, it is common for people to carry out part of their activities, hold investments or have personal and economic ties in more than one country. Uruguay is no exception, and for those arriving from abroad, determining where their tax residency lies can become particularly important.
But what does it really mean to be a tax resident in Uruguay? In practical terms, tax residency determines the connection a person has with Uruguay for tax purposes and, as a result, affects whether their income falls within the scope of the Uruguayan tax system. It is therefore not simply a matter of determining where a person lives or where their domicile is, but of establishing, under the criteria set out in the regulations, when a tax connection with our country exists.
This question becomes particularly important when a person has activities, investments, assets or family ties in more than one State. In these situations, correctly determining tax residency makes it possible to know which tax relationship should be maintained with Uruguay and, when necessary, to prove that status before agencies or authorities in other countries. Uruguayan regulations provide for different criteria to determine the tax residency of individuals, and the Dirección General Impositiva (DGI, the national tax authority) sets out the procedure and the documentation needed to prove it and obtain the corresponding Tax Residency Certificate.
Who can apply for the Tax Residency Certificate? The Tax Residency Certificate may be requested by an individual or a legal entity that needs to prove its tax residency in Uruguay. The application is filed with the DGI and, at the applicant's choice, may be made in person or remotely.
In the case of individuals, who are the main subject of this analysis, it must first be shown that one of the tax residency criteria set out in the regulations is met.
How is the tax residency of an individual proven? The DGI guidelines provide for several criteria to prove the tax residency of an individual: length of stay, base of activities, economic interests and vital interests. These criteria must be analyzed according to the particular circumstances of each case.
1. Presence in Uruguayan territory. One of the best-known criteria is staying in Uruguayan territory for more than 183 days in the calendar year. This ground is proven by the arrival certificate or the certificate of migration movements issued by the National Directorate of Migration (Dirección Nacional de Migración). This criterion is especially relevant for those who spend a significant part of the year in Uruguay, even if they maintain certain ties or activities in other countries.
2. Base of activities. Another criterion is having the main core, or base, of one's activities located in Uruguayan territory. This criterion has a particular feature: it is determined on an annual basis, so the certificate can only be requested and issued for a closed fiscal year. To prove this ground, the nature and source of the income earned during the relevant period must be determined. Where there is income other than that derived exclusively from employment or from pensions generated in Uruguay, the guidelines call for accounting documentation detailing the income obtained, its nature, amount and country of origin. A sworn statement regarding the supporting documentation for the income is also required.
3. Economic interests. Tax residency may also be proven by having the base of one's economic interests located in Uruguayan territory. This criterion covers different types of investments made in Uruguay: real estate investments that in total exceed UI 15,000,000 (as of August 20, 2026, approximately USD 2,552,077); and real estate investments exceeding UI 3,500,000 (approximately USD 595,485 on the same date) made on or after July 1, 2020, provided that actual physical presence in Uruguayan territory of at least 60 days during the calendar year has also been met.
To prove these situations, among other things, notarial documentation is required concerning the property, its acquisition and its continued presence in the applicant's estate. In certain cases, physical presence must also be proven by the certificate of migration movements. The guidelines also cover other scenarios linked to investments in companies, such as those corresponding to promoted investment projects and certain investments that generate new jobs.
4. Vital interests. Finally, there is the criterion concerning the location in Uruguayan territory of the center of vital interests. One of the ways provided for is the presumption derived from the tax residency of the spouse and of dependent minor children. To use this presumption, the family members must have proven their tax residency under one of the criteria provided for, and for a period that includes the one for which residency is to be proven. Residency may also be pursued through other elements that demonstrate the person's connection with Uruguay. The guidelines mention, among others: health coverage, membership in sports clubs, banking transactions and expenses made in the country, studies, medical expenses, employment activity, lease agreements, ownership of real estate and associated expenses, utilities, telephone service, insurance and vehicles. In these cases, the documentation must relate to the period for which the certificate is requested and must effectively demonstrate the person's link to the country.
The importance of documentation. As can be seen, proving tax residency is not limited to a single document or circumstance. Depending on the criterion invoked, migration certificates, accounting documentation, notarial certificates, sworn statements and other elements demonstrating the applicant's specific situation may be needed. It is therefore essential that the information provided in the application match the information on record with the DGI. The guidelines themselves provide that applications containing data different from that recorded in the Single Taxpayer Registry (Registro Único Tributario), or that are not properly completed, will not be processed.
How is the Tax Residency Certificate obtained? The application may be made online, through the DGI Administrative Files (Expedientes Administrativos) system, or in person at the relevant offices. When made online, the form is generated automatically. Once issued, the Tax Residency Certificate is a digitally signed electronic file and is sent to the email address corresponding to the applicant's registered domicile. When applying, the recipient country, the name of the recipient and the transaction for which the certificate is required must also be indicated. If it is needed for more than one recipient, the guidelines provide for the use of the corresponding annex.
Tax residency is not determined solely by the number of days a person stays in Uruguay, but by the whole of their personal, family, economic and professional circumstances. Each situation must therefore be analyzed individually, considering the ties the person maintains with our country.
What does being a tax resident in Uruguay entail? Acquiring tax residency in Uruguay does not mean that all income and all assets a person holds abroad automatically become subject to Uruguayan taxation. In general terms, Uruguay taxes Uruguayan-source income, that is, income derived from activities carried out or rights exploited in the country. However, there are certain exceptions, including income from movable capital obtained abroad by resident individuals (such as interest and dividends), which is taxed.
As for wealth, Uruguay taxes assets located in Uruguayan territory and, in general terms, does not reach assets located abroad. When analyzing the tax consequences of acquiring residency in Uruguay, it is therefore necessary to distinguish between tax residency and the actual scope of the tax obligations that may derive from it. It is not simply a matter of determining where a person is resident, but also of analyzing what income they earn, where it is generated and what assets they hold.
Frequently asked questions. What happens to the tax residency the person previously held in their country of origin? Acquiring tax residency in Uruguay does not necessarily mean the person ceases to be considered a tax resident in their country of origin. Each State determines, under its own regulations, who is considered a tax resident. In Uruguay, the regulations even expressly provide for the possibility that a person may prove their tax residency in another country by means of a certificate issued by the competent tax authority of that State.
Can a person have two tax residencies at the same time? Yes, a person may be considered a tax resident under the domestic law of two States, when each country applies its own criteria and both consider that the person meets them. However, when a Double Taxation Convention exists between those countries, the convention may establish specific rules to resolve this situation. These are the so-called "tie-breaker rules", which determine in which of the two States the person will be considered a resident for the purposes of the convention.
Is legal residency in Uruguay necessary in order to be a tax resident? Not necessarily. Legal residency and tax residency are different concepts and serve different purposes. Tax residency is determined under tax regulations: in Uruguay, individuals are considered tax residents when they meet any of the grounds provided for in the regulations. Therefore, tax resident status does not depend, by itself, on having previously obtained legal residency in Uruguay. What matters, from a tax standpoint, is determining whether any of the criteria established by tax legislation is met.
