2017: A Transparent Year

The end of year is often surrounded by tax news: the desire to close the year, the commitments undertaken with third parties (in this case, the OECD) or even the imminent summer break, tend to encourage such phenomenon.

This year has not been any exception. On December 29, 2016, Uruguayan Parliament passed so-called “Tax Transparency Act” (the “Act”), which introduces three (3) of the main innovations of the Act are:

(i) The obligation of Uruguayan banks to provide to the Tax Office (Dirección General Impositiva — DGI) information regarding their clients at the end of calendar year. According to press sources, such information will be provided in relation to those accounts which would exceed the following thresholds: US$ 50,000 for Uruguayan residents, either individuals or legal entities; US$ 250,000 for non-resident individuals; and US$ 1,000,000 for non-resident legal entities.

(ii) The creation of a registry with the names of the beneficial owners of companies operating in Uruguay (i.e., the names of those individuals who ultimately and effectively control those companies).

(iii) Several amendments to the tax treatment on those non-resident legal entities domiciled in null or low taxation jurisdictions (the “Offshore Companies”). Such amendments tend to discourage the use of Offshore Companies sharply increasing their taxation.