Moving to Uruguay from the UK: taxes before you move

By Matías Zurbriggen, public accountant (CCEAU 225636). Updated 4 October 2026.

Moving from the UK to Uruguay? We assess your Uruguayan tax position and provide a confidential written report in English. Your UK tax position remains with your UK adviser.

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When do I become a tax resident in Uruguay?

Arriving in Uruguay or obtaining a residence permit does not, by itself, determine your tax residency. Immigration residence and tax residency are assessed under separate rules.

For tax, article 2 of Title 7 of the 2023 Ordered Text (TO 2023) and article 5-BIS of Decree 148/007 set out the grounds. Meeting one is enough:

• Physical presence: more than 183 days in Uruguay in the calendar year. Qualifying short absences count as days here unless you substantiate foreign tax residence with a certificate issued by the competent foreign tax authority. That certificate does not prevent Uruguayan tax residency where your actual presence exceeds 183 days.
• Vital interests: the presumption concerns your spouse, provided you are not legally separated, and dependent minor children subject to parental authority who live here habitually. Where there are no children, the spouse's presence is sufficient. The presumption can be rebutted.
• Centre of activities: your main centre of activities may be in Uruguay where you generate more gross income here than in any other individual country. This criterion is not established solely by income that consists entirely of pure capital income. See the DGI's guide to the grounds of tax residence.
• Economic interests: certain investments in Uruguay above the thresholds set by regulation. A foreign tax residence certificate can displace this investment-based presumption. It does not, by itself, rule out Uruguayan tax residency under another criterion.

Uruguay assesses individual tax residency by calendar year, and the DGI issues its certificate for the full year, January to December. Ask your UK adviser to confirm the UK tax periods and residence rules relevant to your move.

Is there a double tax treaty between the UK and Uruguay?

Yes. According to the DGI's official table of treaties:

The DGI also lists this treaty among those modified by the OECD multilateral instrument (MLI), with effect from 1 January 2021.

The treaty can be relevant during and after your move. It addresses residence for treaty purposes and the treatment of different income categories. We assess its application on the Uruguayan side, reading the relevant article with your documents rather than summarising it here.

We advise on the Uruguayan side. Your UK tax position (the statutory residence test, whether split-year treatment applies, and what HMRC needs when you leave) should be confirmed with a UK adviser, and we can speak to that adviser if needed.

How could the Tax Holiday affect my UK investments?

A move can affect the Uruguayan treatment of your investments. We assess the Uruguayan classification of your investment income and whether a statutory option is available. For the general rules, see our Uruguay tax residency guide.

The Tax Holiday is an option to be taxed under IRNR on specified investment income from non-resident entities and gains linked to the assets covered by article 6(2) of Title 7. It does not cover every dividend, interest payment or capital gain. It was added to Title 7 as article 24-Bis by Law 20,446 (article 648), and Decrees 95/026, 188/026 and 225/026 amended the regulations that develop it.

Where the covered income is foreign-source under the applicable IRNR rules (articles 6 and 7 of Title 8) and the election remains valid, it falls outside Uruguay's IRNR charge. This does not establish the treatment of every payment from a non-resident entity. The election covers the year in which you acquire residency plus the ten following years (up to 11 fiscal years). A year in which the conditions are not met does not restart the statutory period. Relief may apply again in a later qualifying year within that period.

Eligibility depends on statutory residence or investment conditions. We assess which conditions are relevant to your circumstances and whether the available evidence supports them. For the initial IRNR option, you must not have been Uruguayan tax resident in either of the two immediately preceding tax years or have used the article 24 regime. Certain former beneficiaries may access the later options provided by article 24-Bis, subject to its conditions. The fund route is subject to the formalities, terms and conditions established by the Ministry of Economy and Finance (Decree 148/007, article 5-SEXIES). Its application must be checked against the requirements in force.

After the initial period, the general IRPF rules apply according to the income concerned, unless a further statutory option is available and elected. These options have separate conditions and time limits; the fixed-amount option is elected annually. A single tax rate should not be assumed for every case (Title 7, article 37; Decree 148/007, article 5-SEPTIES).

Under DGI Resolution 2,158/026 (published 17 September 2026), the initial IRNR election under article 24-Bis is made by a one-off sworn declaration filed with DGI and is irrevocable. For each tax year, you must provide DGI with evidence that the applicable conditions were met, including years with no covered income. The deadline is 31 January of the following year.

Separately, the designated withholding agent must verify the election on DGI's website before paying, crediting or attributing the relevant income (Resolution 2,158/026, number 5; Resolution 1,517/026, number 19). Withholding depends on the applicable rules and option; it should not be confused with the final tax liability.

If you acquired tax residency before 2026, the earlier article 24 regime requires review. DGI Resolution 2,158/026, number 7, allows that election until 31 December 2026.

What if I keep working for a UK employer or UK clients?

The Tax Holiday does not cover your salary or fees. Under article 6 of Title 7, income from activities carried out in Uruguay is Uruguayan-source, whoever pays it. Working from Punta del Este for a company in London is work performed here. The three usual profiles (employee, contractor, company owner) are covered in Moving to Uruguay and working remotely.

What about UK rent and pensions?

If you keep a property in the UK and rent it out, its Uruguayan treatment depends on the ownership arrangements and the income concerned. Do not assume that the Tax Holiday covers rent from a property you own directly. UK tax treatment requires advice from a UK adviser.

UK pension payments require a separate assessment. Uruguay distinguishes pension benefits from investment and insurance income. Pensions arising from contributions to non-resident social security institutions are outside the social security assistance tax (IASS) (article 2 of Title 12), but that does not settle the treatment of every retirement product. UK taxation must be confirmed with a UK adviser. Our separate article covers UK pensions and dividends in Uruguay.

A generic example: same move, two different first years

Take two hypothetical households (not clients) leaving the UK in the same year.

In the first, the whole family arrives in February and stays. The day count will very likely settle residency for that year, and the Tax Holiday conditions can be reviewed from year one.

In the second, one spouse and the children move in September for the school year, while the other spouse stays in the UK to finish a contract. Nobody reaches 183 days. Where the couple are married and the dependent minor children habitually live in Uruguay with the spouse, the person remaining abroad may fall within the rebuttable presumption of vital interests here. The UK may still regard that person as UK resident. This is where the treaty can matter, and where the Uruguayan and UK positions need to be read together.

What not to do

• Don't assume a residence permit makes you tax resident, or that not having one means you are not. They are separate tests.
• Don't count on the Tax Holiday without checking eligibility. Your residence in the two preceding tax years, any previous use of article 24 and the investment routes' formalities all matter.
• Don't expect one adviser to cover both countries. Your UK tax position should be confirmed with a UK adviser.

Where to start

Before you commit to a date, a property or a sale, it helps to know which ground you may meet, in which year, and what the Tax Holiday conditions would require in your case.

Estudio Zurbriggen has operated since 1993. Our two public accountants are registered with CCEAU under numbers 61148 and 225636. In our tax diagnostic, we review your dates, family situation, income and assets. The assessment provides a confidential written report on your Uruguayan tax position. You receive it in English within 3 to 5 working days of our receiving all the information needed. We work mainly in writing, in English; calls are also possible.

Request your written tax assessment in English

Frequently asked questions

Does buying a flat in Uruguay make me tax resident?

Buying a flat does not automatically make you Uruguayan tax resident. The investment criteria require a separate assessment, and qualifying for tax residency does not automatically establish Tax Holiday eligibility.

I moved to Uruguay in 2025. Can I use the new Tax Holiday?

The relevant date is when you acquired Uruguayan tax residency, rather than when you moved. If you acquired it in 2025, the initial IRNR option under article 24-Bis is not available. The earlier article 24 regime requires review; DGI Resolution 2,158/026, number 7, allows that election until 31 December 2026. Certain taxpayers who previously elected IRNR under article 24 may qualify for later options under article 24-Bis, subject to its conditions.

Does the Tax Holiday mean I pay no tax in Uruguay?

No. It is an option for specified investment income from non-resident entities and gains linked to the assets covered by article 6(2) of Title 7. Work you do from Uruguay, Uruguayan-source income and social security contributions are separate.

Does the Tax Holiday cover rent from a UK property?

It depends on the case. If you own the property directly, do not assume that the Tax Holiday covers the rent. The Uruguayan treatment depends on the ownership arrangements and the income concerned, and the UK treatment must be confirmed with a UK adviser.

Will the UK-Uruguay treaty stop me being taxed twice?

It is designed to avoid double taxation. Article 25 of Title 7 also permits a credit for qualifying foreign tax on income covered by article 6(2), subject to the regulatory conditions and the Uruguayan IRPF limit for the same income. It does not guarantee that every instance of double taxation will be eliminated. Whether either mechanism resolves your case depends on the income and the year.

Sources

• Title 7 of the TO 2023 (IRPF): articles 2, 6, 24, 24-Bis, 25 and 37.
• Title 8 of the TO 2023 (IRNR): articles 6 and 7.
• Title 12 of the TO 2023 (IASS): article 2.
• Law 20,446, articles 648, 649 and 653.
• Decree 148/007, consolidated text: articles 5-BIS, 5-SEXIES, 5-SEPTIES, 29-TER, 44-SEXIES and 44-OCTIES. Relevant amendments include Decrees 95/026, 188/026 and 225/026.
• DGI Resolution 2,158/026 (published 17/09/2026), numbers 1 to 7; DGI Resolution 1,517/026, number 19.
• UK-Uruguay double taxation convention (Law 19,443); tax information exchange agreement (Law 19,429).
• DGI, grounds of tax residence and table of double taxation conventions.

By Matías Zurbriggen, public accountant (CCEAU 225636). Estudio Zurbriggen has operated since 1993.