On 2 October 2013, Binding Ruling No. 5,743, issued by the tax authority, was published in the Official Journal. The ruling explains the tax implications of a redomiciliation abroad.
The requesting company is a real estate business, which owns exclusively real estate assets in Uruguay. According to the ruling, once a company is redomiciled abroad, it becomes a non-resident entity for corporate income tax (IRAE) purposes, regardless of whether the assets are located in Uruguay.
Once redomiciled,…