Uruguay

Tax Residency by Investment

Uruguay's Tax Residency by Investment program allows foreign nationals to establish fiscal resident status by making qualifying investments in real estate or business enterprises on Uruguayan territory. The program combines investment-based tax residency with a generous tax holiday exempting foreign-source capital income for up to 11 fiscal years, effectively positioning it as Uruguay's "golden visa" equivalent. Tax residency and legal residency are separate processes -- applicants must obtain legal residency through the immigration authority (DNM) in addition to the tax residency certificate from the tax authority (DGI).

Uruguay offers four distinct investment routes to establish tax residency:

• Option A -- High-value real estate: Investment exceeding approximately USD 2,200,000 (15,000,000 UI) in real estate. No physical presence requirement.
• Option B -- National interest business projects: Investment exceeding approximately USD 6,500,000 (45,000,000 UI) in activities declared of national interest. No physical presence requirement.
• Option C -- Lower-threshold real estate: Investment exceeding approximately USD 500,000 (3,500,000 UI) in real estate made from July 2020 onward, plus at least 60 days of physical presence per calendar year.
• Option D -- Lower-threshold business investment: Investment exceeding approximately USD 2,200,000 (15,000,000 UI) in a company made from July 2020 onward, generating at least 15 new full-time dependent employment positions during the calendar year.

Investment values are assessed in Unidades Indexadas (UI) as of December 31 each year. Real estate must remain owned as of that date for the investment to qualify.

• Foreign nationals of any nationality who make qualifying investments in Uruguay
• Must not have been a fiscal resident of Uruguay during the 2 calendar years preceding the application (for tax holiday eligibility)
• No educational, professional, or language requirements
• For the underlying legal residency: must demonstrate sufficient income to cover living expenses (approximately USD 1,500/month in practice)
• Criminal record certificates for legal residency application

For tax residency certificate (DGI):

• Formulario 5202
• Notarial certificate detailing the investment (price, acquisition date, origin, and property description per the registered purchase agreement)
• Proof of physical presence (60+ days for lower-threshold options)
• Valid identity document

For legal residency (DNM):

• Valid passport or travel document
• Criminal record certificates from all countries of residence in the past 5 years (for stays of 6+ months), apostilled and translated into Spanish
• Health certificate (carne de salud) and vaccination certificate from authorized Uruguayan providers
• Proof of income/means of support
• Passport-sized photograph

Tax residency is maintained annually as long as qualifying conditions are met (investment ownership as of December 31, plus physical presence where applicable). The underlying permanent legal residency is indefinite and does not expire. The cedula de identidad must be periodically renewed as an administrative matter.

New tax residents may elect to pay Non-Resident Income Tax (IRNR) instead of standard income tax (IRPF) on foreign-source capital income for 11 fiscal years (the year of arrival plus 10). This effectively exempts foreign-source dividends, interest, capital gains, and rental income during the holiday period.

From January 2026, new rules apply:

• Those who become tax residents through 183+ days of physical presence alone may access the tax holiday without any investment requirement
• Those who become tax residents through investment (without meeting the 183-day threshold) must invest at least approximately USD 2,000,000 (UI 12,500,000) in real estate, or contribute approximately USD 100,000 (UI 625,000) annually to qualifying investment funds
• After the 11-year holiday expires, two extension options are available: (1) IRPF at 50% of the standard rate for 5 years with qualifying investment, or (2) a fixed annual IRPF amount of approximately USD 300,000 for up to 20 years (reduced to approximately USD 200,000 with 183+ days of presence)
• IRPF at 12% now applies to previously untaxed foreign capital sources including foreign real estate rentals and capital gains from foreign investments

Uruguayan-source income is taxed under normal IRPF rates: 0-36% progressive rates on employment income, 12% flat rate on capital income.

The process involves two parallel tracks:

1. Legal residency (DNM): Submit an online application via gub.uy, pay the processing fee (approximately USD 83 / 557.30 UI), and attend an in-person interview with original documents at a DNM office. A provisional identity card is issued within approximately 10 days of the biometric appointment.
2. Tax residency (DGI): Once the qualifying investment has been made, submit Formulario 5202 via DGI's online services portal with notarial certification of the investment and proof of physical presence where required.

Most nationalities can enter Uruguay visa-free for up to 90 days as tourists, providing time to begin both processes. Mercosur and associated state nationals benefit from a simplified permanent residency track. Total processing time for legal residency is typically 6-12 months.

Spouses, cohabiting partners (concubinos), and minor children apply independently for legal residency through DNM. Each family member's application requires its own set of documents, fees, and criminal background checks. For tax residency purposes, a spouse's or dependent minor children's habitual residence in Uruguay may independently establish the "vital interests" criterion -- a separate basis for tax residency that does not require any investment.

For Option C (real estate above USD 500,000): a minimum of 60 days of effective physical presence per calendar year is required. For Options A and B (higher thresholds): no physical presence requirement. All days of effective physical presence count regardless of entry/exit time. Sporadic absences of up to 30 consecutive days count toward the total unless the person demonstrates fiscal residency elsewhere.

Permanent legal residents may apply for Uruguayan legal citizenship after 3 years if married or with Uruguayan children, or 5 years if single. Naturalization requires demonstrating integration and conversational Spanish proficiency. Uruguay fully allows dual citizenship and does not require renunciation of existing nationality.

Links

• https://www.gub.uy/tramites/solicitud-certificado-residencia-fiscal-persona-fisica
• https://www.impo.com.uy/bases/decretos/148-2007/5_BIS
• https://www.gub.uy/tramites/residencia-legal-permanente
• https://www.gub.uy/direccion-general-impositiva/comunicacion/publicaciones/causales-residencia-fiscal

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