Transfer Pricing - Country by Country Report

By CPA María Noel Fernández


We inform that by Law 19.484, those Uruguayan entities that are part of a Multinational Group of great economic dimension, are required to file before the Uruguayan tax authority (DGI) a “Country by Country Report” and a “Master Report” for fiscal exercises started since January 1st 2017. This law has recently being regulated given the criteria and deadlines for submitting these reports.

This regulation defines a Multinational Group of great economic dimension as one which consolidated total revenues at the end of the group's fiscal year are equal to or greater than EUR 750,000,000 (Euros seven hundred and fifty million) or its equivalent in the presentation currency of the Group.

Prior to the presentation of the aforementioned reports, the following information must be communicated to the DGI in annual basis (prior to the closing date of the financial exercise of the Group):

  1. Data of the entity that will present the Country by Country Report on behalf of the Multinational Group
  2. The final controlling entity of the Multinational Group
  3. The entities of the Multinational Group in the country

For the financial exercises ended between December 31st, 2017 and February 28th, 2019, the deadline to submit this information expires on March 31st, 2019.

In order to assess whether you are included in this obligation or not, please inform us the global income of the Multinational Group in the latest consolidated financial exercise of the group.

In case the group's income exceeds EUR 750,000,000, please inform us of the following:

  1. In which jurisdiction the controlling entity of the Group is a tax resident and if in such jurisdiction the Group is considered of great economic dimension according to the legislation of that country.
  2. If the Uruguayan entity is included in the consolidated statements of the Multinational Group for the purposes of its presentation and if it is not, if this is because it does not correspond or if it is for reasons of size or relevance.
  3. If the controlling entity of the Group submits the Country by Country Report in its jurisdiction.

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