Uruguay Clarifies Repatriated PE Profits Not Subject to Non-Resident Income Tax Under Tax Treaty with Belgium

Uruguay recently published Tax Consultation No. 6490 from the Directorate General of Taxation (DGI) regarding the application of Non-Resident Income Tax (Impuesto a las Rentas de los No Residentes - IRNR) on the repatriated profits of a permanent establishment (PE) in Uruguay to a company resident in Belgium. The consultation is in response to a request from a PE in Uruguay of a foreign company resident in Belgium, which sought to clarify the application of the 2013 Belgium-Uruguay tax treat…