Uruguay Issues Draft Tax Amendment Measures Introducing Loss Utilization Restrictions, Deemed Dividends Taxation, and Other Changes

Uruguay's Ministry of Economy has issued draft tax amendment measures that include:

• Restricting the deduction of carried forward losses to 50% of taxable profit each year (Uruguay allows losses to be carried forward up to five years, which will not be changed);
• Levying the 7% dividends withholding tax on undistributed profits retained for more than three years in proportion to non-resident shareholding (deemed dividend), with an exemption for reinvested profits;
• Reducing the value added tax …