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On December 8, 2017, Uruguay’s Executive Power enacted Law No. 19,566, introducing changes to Law No. 15,921, which established the Free Trade Zone (FTZ) regime. The changes are effective March 8, 2018.
The new law allows services rendered to third countries from the FTZ to also be rendered from the FTZ to corporate income taxpayers inside Uruguayan, non-FTZ, territory.
The new law states that the requirement for 75% of an FTZ user’s employees to be Uruguayan could be reduced with authorization of the Executive Power under certain circumstances. When granting the authorization, the Executive Power could additionally require the users to implement training programs with the purpose of reaching the minimum quota of Uruguayan citizens. For service activities, the Executive Power could reduce the minimum employment requirement to 50% when the nature of the business deems it necessary.
FTZ providers outside of the metropolitan areas will be tax-exempt, except for corporate income tax purposes, Social Security contributions and legal benefits of pecuniary nature established in favor of non-state public social security persons (e.g., certain retirement and pension funds).
The new law allows the Executive Power to authorize the use of thematic service zones — which will be FTZs — outside the metropolitan area, to provide audiovisual, amusement and entertainment services (different from gambling) and complementary activities. Corporate income tax and value added tax exemptions will only apply to services rendered to non-Uruguayan tax resident final consumers.
In light of the new regulations, current FTZ users will be able to maintain the benefits and exemptions granted before the effective date of this law, and no limitations will apply to them as a result of the changes.