Country-by-Country Report in Uruguay: Its Implementation Will Begin Soon

Multinational enterprises (“MNEs”) with premises or operations in Uruguay must submit to the Tax Office a Country-by-Country report (“the CbC report”) along the OECD guidelines. Such report must contain detailed information on the branches and other MNE related entities around the world. Due date is 31 March 2019. The obligation to submit the CbC report applies to those MNEs with an annual worldwide gross income in excess of EUR 750 million. Even where such annual threshold is met by the group, MNEs are required to submit the Country-by-Country report only where such report is not filed in any other jurisdiction which has tax information exchange agreement (in force) with Uruguay (“TIEA”). Where the CbC report is filed by the MNE in other jurisdiction (and where there is a TIEA in place with Uruguay), MNEs are still required to submit --with Uruguay’s Tax Office-- a sworn statement, in order to identify: (a) the foreign entity responsible for the filing of the CbC report on behalf of the MNE group, (b) the controlling entity of the MNE group, and (c) the name of other entities of the MNE group in Uruguay, if any. Bergstein transfer pricing practice team assists multinational companies in the filing of the above information.

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