Uruguay specifies IMCD fiscal-stability compensation procedure

The resolution, dated 23October, implements Decree 206/026 rather than creating a new exemption. Under that decree, affected multinational-group entities remain subject to formal obligations and payment. Compensation depends on an eligible pre-existing fiscal-stability clause and accounts for any reduction in foreign taxes resulting from the Uruguayan IMCD payment.^[1][2]

An applicant must first submit a sworn declaration requesting compensation. The declaration releases DGI from tax confidentiality only for the information it contains, allowing communication to the BEPS Inclusive Framework. The administrative dossier follows that declaration, rather than replacing it.^[1]

The dossier identifies the taxpayer, applicable stability clause and group structure. It includes an audit report supporting the inability to credit all or part of the IMCD elsewhere, with the relevant law, ownership chain and foreign-tax exposure. Translation where necessary, legalisation and apostille requirements apply. It also includes the relevant country-by-country report, an explanation of changes from the previous year and proof of the earlier declaration. DGI may request further information.^[1]

Compensation is realised through the relevant IMCD return. Applying it against payment requires compliance with the declaration and dossier requirements and a favourable DGI decision before the existing tax-obligation deadline. Decree 206/026 already provided the timely-decision route; the resolution supplies procedural detail, not a new general due date.^[1][2]

Groups should therefore align their claim evidence and decision timetable with the existing return and payment process. Neither an application nor a fiscal-stability label alone establishes a right to stop paying the tax.^[1][2]