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HMRC internal manual

Double Taxation Relief Manual

Uruguay: Treaty Summary

The table summarises the provisions of the treaty as they relate to income beneficially owned by UK residents. The rate shown is the ‘treaty rate’ and does not reflect taxes chargeable under domestic law before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which Uruguay is permitted to tax income in the relevant categories under the treaty. Rates chargeable under domestic law may be higher or lower.

In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details. The text of the treaty can be found on gov.uk.

 

Portfolio dividends 15% Article 10
     
Dividends on direct investments 5% Article 10
Conditions for lower rate on dividends on direct investments The beneficial owner must be a company which holds directly at least 10% of the capital of the payer Article 10
Property income dividends 15% Article 10
Interest 10% (note 1) Article 11
Royalties 10% Article 12
Government pensions Taxable only in Uruguay unless the individual is resident in, and a national of, the UK Article 18
Other pensions Exempt from tax in Uruguay  if not exempt from tax in the UK Article 17, Article 20
Arbitration Yes Article 25

 

Note 1: Interest is taxable only in the state of residence of the beneficial owner where such interest is paid:

  • to a financial institution on a loan of at least three years for the financing of investment projects;
  • to that other State, its political subdivisions or local authorities or to its Central Bank or other entity wholly-owned by that State, political subdivision or local authority;
  • by the State in which the interest arises or by a political subdivision or local authority thereof;
  • in respect of a loan granted by, or guaranteed or insured by, that other State or a political subdivision, local authority or export guarantee department thereof; or
  • to a pension scheme, provided that  the debt-claim in respect of which such interest is paid is held for the purpose of  pension provision.