Uruguay master file and local file requirements (2026)

Which transfer pricing documents does Uruguay require?

Three documents and one notification. The sworn statement and local file follow the Uruguayan entity's own numbers. The master file and the country-by-country report follow the group, and only a large one. The trigger and the deadline for each are below, with the institution that publishes the rule.

The local file trigger, the nine-month deadline and the Spanish-language rule are all set out in the OECD transfer pricing country profile for Uruguay^[1], updated in February 2022.

Do I need a master file or a local file in Uruguay?

The local file turns on your own transactions, the master file on your group's size. Cross 50 million UI of controlled transactions in the year and the local file is due. Belong to a group with EUR 750,000,000 or more of consolidated revenue and the master file is due as well. A smaller group with a busy Uruguayan entity files the local file alone.

Uruguay sets no ownership percentage for a related party. Two companies are related when they share management or control, or when one can steer the other through capital, credit or a contract. Deal with a company in a low-tax or nil-tax jurisdiction and the DGI presumes you are related, whether or not anybody owns anybody. For the framework your Uruguayan obligation sits inside, see our guide to master and local files in transfer pricing.

What goes in the Uruguay master file?

The group's story, on the standard OECD template: organisational structure, a description of the business, intangibles, intercompany financing, and the group's financial and tax positions. It has applied to Uruguayan entities in groups at or above EUR 750,000,000 of consolidated revenue for fiscal years beginning on or after 1 January 2017, under the 2018 reporting decree published in Uruguay's official gazette^[2].

The master file's own filing deadline is not confirmed, and we will not publish a date the primary sources disagree on. The 2022 OECD country profile says Uruguayan law provides for a master file but the decree needed to enforce it has not been issued. The decree that sets master file content has been in force since fiscal years from 1 January 2017. We take the content and the threshold from the decree and leave the standalone deadline open. Ask your Uruguayan adviser which date the DGI is working to before you plan around one.

What goes in the Uruguay local file?

A study, not a file note. It sets out each controlled transaction, the method chosen for it, the comparables behind that method and the economic analysis that makes the price an arm's length one. It is lodged with the annual transfer pricing sworn statement (declaración jurada) and the entity's financial statements, within 9 months of fiscal year end.

The filing step is what catches groups out. A regime that keeps documentation on hand gives you until an audit to finish the work. Uruguay gives you nine months and then wants the study itself. Our transfer pricing documentation guide sets out what a defensible local file carries.

How does Uruguay test your benchmarking?

With one hard number on top of the usual comparability analysis. A price inside the interquartile range of the comparables is accepted. A price outside it is adjusted to the median value, plus or minus 5%, under the transfer pricing implementing regulation published in the official gazette^[3]. There is no stated preference for Uruguayan comparables, and the refresh cycle for a comparables set is not confirmed.

That median reset is the whole reason to build a benchmarking study properly. Sit below the first quartile or above the third and the DGI does not negotiate about where in the range you should have been. Our transfer pricing benchmarking page covers how to build a range that holds.

What are Uruguay's country-by-country reporting rules?

A Uruguayan entity in a group with EUR 750,000,000 or more of consolidated revenue owes a country-by-country report, due 12 months after the reporting fiscal year ends. A separate notification naming the filing entity, the ultimate parent and the Uruguayan group entities is due before the group's fiscal year ends, under the DGI resolution on country-by-country filing^[4].

The notification runs ahead of the year it reports on rather than after it, which is why it is the deadline most often missed. The report itself may be filed in English or Spanish. It is the one exception to the Spanish-only rule.

Which form does the DGI require?

The annual transfer pricing sworn statement, filed with the financial statements and the local file, within 9 months of fiscal year end. The form number is not confirmed. The DGI form index blocked automated access while this page was researched, so we describe the filing by what it does rather than assert an identifier we could not check. The submission is lodged through the DGI's own portal^[5].

What are Uruguay's transfer pricing deadlines in 2026?

Three clocks run off the fiscal year end and one runs ahead of it. Against a 31 December 2025 year end, the local file and sworn statement are due by 30 September 2026 and the 2025 country-by-country report by 31 December 2026, while the notification for the 2026 group year also falls before 31 December 2026.

A shared compliance calendar keeps those dates visible across every entity in the group.

What language and currency does Uruguay require?

Spanish, for everything filed with the DGI. A document in another language has to be translated and legalised first. A local file written in English by a foreign parent is not a filed local file until it has been through that. The country-by-country report alone may go in English or Spanish.

Thresholds are set in indexed units rather than pesos because the unit moves with inflation and a peso figure would be stale within a year. The 2026 peso equivalent is not confirmed from a primary source, so this page does not state one. EUR 5.3 million is the OECD profile's own approximation of the 50 million UI line.

What happens if you miss a Uruguay transfer pricing filing?

Graduated fines, scaling with how serious the failure is, for a missing, late or incomplete transfer pricing filing or country-by-country report. The amounts are not confirmed. The OECD profile gives euro approximations only, and one of the bounds does not render cleanly in the source, so we state the rule and leave the figure to your adviser rather than publish a number we cannot stand behind.

The fine is only half of it. The DGI can also reopen the year and assess, which is the larger number in most cases.

What is the parent company exposed to?

An adjustment, and a long window in which to make it. A price outside the interquartile range is reset to the median, plus or minus 5%. The DGI can assess for 5 years, and for 10 years in certain cases. The low-tax-jurisdiction presumption widens the net further, pulling in counterparties the group has no ownership link to at all.

An advance pricing agreement caps that risk. Uruguay offers unilateral, bilateral and multilateral agreements, each running three years from the year after signature. Short of one, a clean set of intercompany agreements and a filed local file are what defend the margin when the DGI opens a review.

How does Uruguay differ from the OECD baseline?

Uruguay is not an OECD member. It is an Inclusive Framework member^[6], and it follows the OECD Guidelines as soft law, with Chapter III applied. Five differences change what you actually have to do.

One more point. Uruguayan law allows notional profit regimes, but the Executive has never switched the power on, so there is no operative safe harbour here to rely on.

How we help with Uruguay transfer pricing

Uruguay files what most countries only keep, prices its thresholds in units that move with inflation, and wants the whole thing in Spanish. We build the comparables and the economic analysis, draft the local file and the master file, and file them with the DGI inside the nine-month window. See how our transfer pricing software works.

Book a demo to get a Uruguay documentation exposure review before your next filing date.