Uruguay and the United States have signed a Tax Information Exchange Agreement (“IIA”), which will enter into force one month after Uruguay notifies the United States in writing that it has approved the agreement by law. There is no set time frame for this to happen.
I. Current Framework for the Exchange of Tax Information in Uruguay
Uruguay has already signed 39 bilateral instruments of this type, 14 are IIAs as the reference, and 25 are Double Taxation Avoidance Agreements (“DTAs”). In all cases, mechanisms are established to exchange tax information spontaneously and upon request. In practice, the Directorate General of Taxation (“DGI”, under delegated powers of the Ministry of Economy and Finance) receives and makes requests for tax information within the framework of these agreements (especially with Argentina and Spain).
Uruguay has also approved the Multilateral Convention on Mutual Administrative Assistance of the Organization for Economic Cooperation and Development (“OECD”) by Law No. 19.428; and through Fiscal Transparency Law No. 19,484, Uruguay has incorporated the internal CRS (Common Reporting Standard) framework to carry out the automatic exchange of financial information for tax purposes. In this way, Uruguay has been exchanging tax information linked to bank accounts since 2017, and currently receives information from 104 countries, while reporting to 76.
II. The IIA with the United States
