The government adjusts the global minimum tax and modifies the article on bank secrecy.
The global minimum tax was one of the most controversial points of the budget bill presented by the Uruguayan government. The first lines of the document established that this tax would apply to companies with an annual turnover of more than €750 million. However, after receiving criticism from business leaders and opposition legislators, the Ministry of Economy and Finance (MEF) introduced key changes.
During his appearance before the Chamber of Deputies , Minister Gabriel Oddone clarified that the global minimum tax will only apply to companies that already pay taxes in the country where their headquarters are located. In other words, if the company is located in a jurisdiction that does not impose this tax, as is the case with some US firms, it will not have to pay it in Uruguay.
Adjustments to the global minimum tax after criticism from business leaders and legislators
The Ministry of Economy reformulated the scope of the global minimum tax to exclude companies that do not pay taxes in their countries of origin. The measure seeks to preserve legal guarantees and avoid negative impacts on free trade zones.
Oddone cited UPM, a Finnish company with two pulp mills in the country, as an example. He explained that the tax will be "neutral" for that company, since it pays it in Finland. Uruguay will issue a certificate that can be submitted to the tax authorities of origin to avoid double taxation.
Furthermore, the Ministry of Economy and Finance (MEF) confirmed that companies operating in free trade zones will be exempt from the global minimum tax, provided they have prior legal commitments that prevent the imposition of new taxes. This is the case with Pepsico, whose parent company is not subject to the global tax and operates under a contractual framework that guarantees fiscal stability .
On the other hand, the article that authorized the General Tax Directorate (DGI) to lift bank secrecy without a court order was also reformulated. The new version establishes that a judge must rule within ten days. If this is not done, the secrecy will be automatically lifted.
Oddone maintained that the changes seek to comply with the recommendations of the Organization for Economic Cooperation and Development (OECD), without affecting legal certainty or the country's commitments. "We were responsive to the requests we received," the minister stated, while emphasizing the need to preserve citizen protections.
From the opposition, doubts persist. Representative Sebastián Andújar, of the National Party, questioned the measure, stating that "it's the same dog with a different collar." He stated that his party will not support initiatives that involve new taxes, considering that they change the rules of the game.
In addition to the adjustments to the global minimum tax and bank secrecy, the bill includes other tax measures that have generated debate. Among them, it proposes applying VAT to digital platforms like TEMU, in line with what already occurs with services like Netflix and Spotify. This measure seeks to equalize tax treatment between local and foreign providers and broaden the tax collection base.
A tax on foreign deposits is also proposed, with the aim of discouraging capital flight and improving financial traceability. According to sources from the Ministry of Economy , this initiative aims to strengthen fiscal control without affecting small savers or those operating within the formal system.
Regarding the global minimum tax, the government emphasized that its implementation responds to international commitments made by Uruguay within the framework of the OECD. This organization promotes tax standards to prevent large companies from evading taxes by shifting their profits to countries with low or no tax burden.
Oddone emphasized that Uruguay is not seeking to apply taxes retroactively or affect the competitiveness of free trade zones. "There are legal guarantees that the country must respect. We cannot unilaterally change the rules of the game," he stated.
For their part, business sector representatives expressed concern about the uncertainty generated by the tax changes. In meetings with MEF authorities, they requested greater clarity on the scope of the global minimum tax and its impact on foreign investment.
In Parliament, some ruling party legislators supported the adjustments, although they called for continued dialogue with economic stakeholders. "It's important that the budget reflect fiscal responsibility, but also legal stability," said a source from the Broad Front.
The parliamentary debate will continue in the coming weeks, focusing on tax articles and the financing of social policies. Meanwhile, the government is seeking to balance international demands with the specificities of the Uruguayan system , in a context where every peso counts and making ends meet remains a challenge for many families.
