Uruguay has issued the regulations for the Program to Promote the Attraction of Qualified Talent, created by Budget Law No. 20,446 for 2025–2029 and in force since 1/1/2026. Decree No. 257/026 of October 26, 2026, defines which companies are covered and how the options are exercised.
The program allows people who move to Uruguay to work as employees to pay the Non-Resident Income Tax (IRNR) at a 12% rate on their salary, instead of the Personal Income Tax (IRPF) at progressive rates of up to 36%. It revives the scheme introduced in 2023 for the information technology sector and extends it to other sectors.
Requirements for the employee
- Prior residence: not having been a tax resident of Uruguay in the five fiscal years before the move.
- Physical presence: at least two-thirds of the days of the calendar year, or of the contract period if it does not cover the full year.
- Employment income: all of it must be earned in Uruguay and exclusively as an employee.
Covered companies
The regime applies to people working for scientific and technological companies or institutions, companies engaged in innovation or technological development, or companies that provide global services. The Decree treats as such those whose main activity is registered with the Tax Administration (DGI) under one of the ISIC codes it lists, provided they actually carry out those activities and have regular and permanent operations in the country.
The codes include those for the pharmaceutical industry, software development, telecommunications, research and development, holding companies and higher education.
Benefits and term
- IRNR at 12%: the employer withholds the tax from the monthly salary.
- Social security: those who opt for IRNR may also choose not to make contributions to the Social Security Bank (BPS).
- Term: the options are exercised only once, at the start of the employment relationship, and apply for that year and the following four. They are kept after a change of employer if no more than one year passes between the two jobs.
If the physical presence or income requirements are not met in any year, the benefit is lost for that year and the following ones. People who started their employment between March 1 and December 31, 2025, may also apply for the regime from the date the Law came into force.
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