Uruguay Tax Residency 2026 for Argentine Buyers: What Changed in the Tax Holiday, and What Happens if You Invest Less Than USD 2 Million
INGAR · · Analysis
The short answer: if you're planning to buy property in Uruguay for somewhere between USD 150,000 and USD 500,000, that purchase is not enough on its own to unlock the Tax Holiday through the real-estate route in force since 2026. The new legal threshold is more than UI 12,500,000 — around USD 2.06 million using the values cited in this article.
That doesn't mean the regime is off the table for anyone investing less. Article 24-Bis also allows for an annual capital contribution to certain investment funds, plus a no-investment route for anyone who meets the residency test of spending more than 183 days in the country in each tax year.
The practical distinction is a different one: buying an apartment for USD 150,000 to 500,000 no longer works, by itself, as a way into the Tax Holiday. In that price range, the real-estate tax break worth paying attention to is the promoted-housing regime (vivienda promovida), provided the unit, the lease and the remaining benefit period all check out.
Why we wrote this
You'll still find articles out there talking about "tax residency from roughly USD 600,000" and an eleven-year Tax Holiday as though the two were one and the same.
They aren't. Those figures come from different rules:
- The USD 577,000 ballpark comes from a tax-residency presumption that requires more than UI 3,500,000 in real estate plus at least 60 days of physical presence.
- The eleven tax years belong to the inbound-resident regime.
- Since 2026, the real-estate route into that regime requires more than UI 12,500,000.
- None of these amounts grants legal residency or citizenship.
A purchase can deliver solid rental income, preserve capital, or be part of a move abroad. What it shouldn't rest on is a tax benefit that doesn't actually apply to your situation.
Legal residency, tax residency and the inbound-resident regime
| Concept | What it determines | What it doesn't |
|---|---|---|
| Legal residency | Your immigration right to live in Uruguay | Tax residency |
| Tax residency | Your status as a resident taxpayer under the tax code | Your immigration right to live in the country |
| Inbound-resident regime | An optional tax treatment for certain investment income earned by certain new tax residents | It grants neither legal nor tax residency, and it doesn't exempt you from every tax |
Buying property does not automatically give you legal residency, citizenship or access to the inbound-resident regime. Depending on the amount and on how much time you spend in the country, the investment can help trigger a tax-residency presumption.
We go deeper on this in legal residency, tax residency and citizenship: three different things and in does buying property get you residency in Uruguay?.
What happened to the 7% option
For anyone acquiring tax residency from 2020 onward, article 24 offered a choice between:
- Being taxed as a non-resident during the year of the change and the ten years that followed.
- Paying IRPF (Uruguay's personal income tax) at 7% on the covered income, with no time limit.
Ley 20.446 established that the article 24 option could be exercised once only, through December 31, 2025.
As a result, someone acquiring Uruguayan tax residency for the first time in 2026 can no longer choose the open-ended 7% under that article. Neither can someone who became a resident earlier but let the deadline pass without making the election.
It's a different story for anyone who validly exercised the option before the end of 2025. They stay under the treatment they chose, for the applicable term. The change doesn't undo elections already made.
Source: Title 7 of the 2023 Consolidated Tax Code, article 24.
The regime that applies from 2026: article 24-Bis
Anyone who acquires Uruguayan tax residency on or after January 1, 2026 may elect to have certain investment income taxed under IRNR (the non-resident income tax) for:
- The tax year in which the change of residency occurs.
- The following ten tax years.
That's eleven tax years in total.
The election applies only to the income described in article 6, paragraph 2 of Title 7: investment income and capital gains tied to foreign assets or entities.
Because IRNR is, broadly speaking, built around Uruguayan-source income, applying it to the covered foreign income produces what everyone calls the Tax Holiday. It does not turn you into a non-resident for the rest of your tax obligations.
The three routes the law provides
| Route | Legal requirement |
|---|---|
| Real-estate investment | Invest more than UI 12,500,000 in property, subject to the implementing rules |
| Investment funds | Contribute at least UI 625,000 per year to funds that finance productive projects, research or applied innovation |
| Physical presence | Meet the more-than-183 day test in each tax year, with no minimum investment |
In every case, the individual:
- Must acquire Uruguayan tax residency.
- Must not have been a Uruguayan tax resident during the two immediately preceding tax years.
- Must not have used the prior regime, other than in the transitional situations expressly provided for.
- Must make the election under the conditions set by the implementing rules and by DGI (Uruguay's tax authority).
Source: Ley 20.446, article 648.
A note on the implementing rules
The statute leaves it to the implementing decrees to define the conditions attached to the real-estate investment and to eligible funds.
As of August 1, 2026, Decreto 95/026 and Resolución DGI 1517/026 implement parts of the new treatment of foreign income, the withholding mechanics and how the election is evidenced. They do not, however, spell out all the operational conditions for the article 24-Bis investments.
So while the UI 12,500,000 threshold is live in the statute, anyone structuring a deal around that route first needs confirmation on:
- Which properties count toward the total.
- The earliest date from which the investment must be made.
- How it is valued and adjusted over time.
- How long it has to be held.
- What documentation DGI will require.
The same caution applies to fund contributions: not every investment fund automatically qualifies.
UI 12,500,000 does not make you a tax resident
The article 24-Bis investment is a condition for accessing the benefit, not a standalone basis for tax residency.
First you have to acquire tax residency through one of the existing tests:
- Spending more than 183 days in the country.
- Having your principal base of activities in Uruguay.
- Having your center of vital interests there.
- Having your center of economic interests there.
- Meeting one of the real-estate or business-investment presumptions set out in the regulations.
Only then does the question of whether you can make the article 24-Bis election come into play.
This distinction matters all the more because UI 12,500,000 is less than the UI 15,000,000 required by the general real-estate presumption. Investing UI 12,500,000, with nothing else behind it, is not enough to claim Uruguayan tax residency.
What the Tax Holiday covers — and what it doesn't
| Situation | General treatment |
|---|---|
| Foreign investment income and capital gains covered by article 6, paragraph 2 | May be taxed under IRNR for the article 24-Bis period |
| Employment income | Not covered by this election |
| Rent from a property located in Uruguay | For a resident, normally subject to IRPF unless an exemption applies |
| VAT, Contribución Inmobiliaria (municipal property tax) and Impuesto de Enseñanza Primaria (primary-education tax) | Still apply regardless of the election |
| Net wealth tax | Analyzed separately |
| Legal residency and immigration status | Unaffected by the tax election |
This is not a blanket exemption, and it doesn't let you treat all of your income as though you had stopped being a resident. It's a narrow regime aimed at specific categories of investment income.
The real-estate routes to tax residency
Article 5-Bis of Decreto 148/007 sets out two presumptions built on real-estate investment.
| Presumption | Investment required | Physical presence |
|---|---|---|
| General real-estate investment | More than UI 15,000,000 | No specific day minimum under this provision |
| Investment made on or after 7/1/2020 | More than UI 3,500,000 | At least 60 days of actual physical presence during the calendar year |
For these thresholds, what counts is the indexed tax cost of the property — not necessarily its list price or a commercial appraisal.
There are also presumptions tied to business investment:
| Business investment | Additional condition |
|---|---|
| More than UI 45,000,000 | A company whose activities or projects have been declared of national interest under Ley 16.906 |
| More than UI 15,000,000, made on or after 7/1/2020 | Creation of at least 15 new direct, full-time employee positions |
With these economic-interest presumptions, the individual can rebut them by proving tax residency elsewhere through a certificate issued by the competent foreign tax authority.
Sources: Decreto 148/007, article 5-Bis and DGI — Grounds for tax residency.
What the thresholds look like in dollars
To make the amounts comparable, we're using:
- The UI (Unidad Indexada, Uruguay's inflation-indexed accounting unit) as of 8/1/2026: $ 6.6300.
- The BCU (Uruguay's central bank) dollar rate as of 7/29/2026: $ 40.223.
| Threshold | Approximate USD equivalent |
|---|---|
| UI 625,000 | 103,000 |
| UI 1,250,000 | 206,000 |
| UI 1,875,000 | 309,000 |
| UI 3,500,000 | 577,000 |
| UI 6,250,000 | 1,030,000 |
| UI 12,500,000 | 2,060,000 |
| UI 15,000,000 | 2,472,000 |
| UI 45,000,000 | 7,417,000 |
Sources: INE — Unidad Indexada, July 2026 and BCU — Exchange rates.
Treat these as reference conversions. The rules are written in UI, and no fixed dollar figure is guaranteed.
Before you rely on any dollar figure
Ask whoever gives it to you:
- Whether the threshold belongs to a tax-residency test or to a condition of the inbound-resident regime.
- Which article, and which version of the rule, is being applied.
- The date of the UI value and of the exchange rate.
- Whether physical presence is also required.
- How the indexed tax cost of the investment is calculated.
- Whether the route in question already has enough implementing regulation to be workable.
Without those specifics, a dollar figure tells you very little.
What this means for a USD 150,000 to 500,000 purchase
| Goal | Does the purchase get you there? |
|---|---|
| Article 24-Bis via real-estate investment | No. The threshold works out to roughly USD 2.06 million |
| Article 24-Bis via physical presence | Possibly, though the purchase isn't what triggers the benefit; you need to clear 183 days in each tax year |
| Article 24-Bis via investment funds | Possibly, subject to contributing UI 625,000 a year to eligible funds and to the implementing rules |
| Tax residency via UI 3,500,000 plus 60 days | Not on that budget alone, since the threshold currently works out to about USD 577,000 |
| Promoted housing | Possibly, if the unit and the lease meet the conditions |
The article 24-Bis real-estate threshold sits roughly 4.1 to 13.7 times above the purchase range we're looking at.
The practical takeaway: an apartment purchase in the USD 150,000 to 500,000 range shouldn't be justified by the real-estate Tax Holiday. If the buyer is actually relocating and will meet the day-count test, or is also structuring an investment in eligible funds, the analysis looks different.
For someone focused purely on rental returns, promoted housing is usually the tax incentive that attaches directly to the unit itself.
The benefit that can genuinely apply: promoted housing
Ley 18.795 and Decreto 355/011 grant benefits to units covered by a promotional declaration.
For a buyer who plans to rent the property out, the main ones are:
| Benefit | Scope |
|---|---|
| IRPF, IRAE (corporate income tax) or IRNR on rental income | 100% or 60% exemption, depending on the zone and the conditions |
| Net wealth tax | Exemption for the statutory period, conditional on the property being leased |
| ITP (property transfer tax) | Exemption for both buyer and seller on the first transfer, within the applicable window |
| VAT | Exemption on the first transfer |
There's no minimum purchase price. What matters isn't whether the unit costs USD 120,000 or USD 500,000, but rather:
- Whether it is genuinely covered by a promotional declaration.
- What exemption percentage applies to its zone.
- Which tax year construction was completed in.
- How many years of benefit are left.
- What the lease will be used for and how long it will run.
Rental income may be 100% or 60% exempt
Decreto 355/011 provides for:
- A 100% exemption for homes located in zones designated by MVOT (the housing ministry), or leased with an FGA (the state rent-guarantee fund) or another approved guarantee.
- A 60% exemption for all other promoted leases.
The 2020 regulations grant, broadly speaking:
- 100% in Montevideo areas 01 and 02.
- 100% in area 03 only under the specific conditions set out in the regulations.
- 100% in approved cities outside Montevideo.
You can't assume a percentage just because the listing says "Ley 18.795." Check the declaration, the location and the regime that actually applies.
The clock doesn't start when you buy
The rental-income exemption runs for the tax year in which construction is completed plus the following nine.
Example: if the building was finished in 2022, the clock doesn't restart when you buy in 2026. You get whatever years are still left under the declaration.
For net wealth tax:
- There's an exemption in the tax year construction is completed.
- In each of the nine following years, the home must have been leased for at least six months for the benefit to apply.
The lease has to be for permanent housing
The rental benefits require:
- Use as a permanent residence.
- A lease term of 12 months or more.
Short-term and vacation rentals don't qualify.
ITP and VAT apply only to the first sale
The ITP exemption covers both buyer and seller on the first transfer, as long as it takes place no later than nine tax years after the year construction was completed.
The VAT exemption is likewise tied to that first transfer. A later resale doesn't get those exemptions again.
Sources: Ley 18.795, Decreto 355/011, articles 10 and 12 and Implementing regulations for Ley 18.795.
A regime that could change again
The 2025-2029 Five-Year Housing and Habitat Plan proposes a review of the existing promoted-housing incentives. The document takes issue with some of the effects of the 2020 regulations, among them the concentration of small units and the removal of several marketing conditions.
That signals where policy may be headed, but on its own it doesn't change the benefits currently in force. Until a new rule is passed, the current regulations apply — and it's worth verifying them again before you put down a deposit.
Source: 2025-2029 Five-Year Housing and Habitat Plan.
What happens after the eleven years of article 24-Bis
The new regime doesn't necessarily end when the initial Tax Holiday expires.
Once the eleven years are up, article 24-Bis offers two alternatives.
Option 1: IRPF at 50% of the applicable rate
This can apply for five additional tax years, provided one of these conditions is met:
- Contributing UI 625,000 a year to the funds the rule specifies.
- Making real-estate investments of more than UI 6,250,000, subject to the implementing rules.
Where the ordinary rate is 12%, 50% of it comes to 6%. Decreto 95/026 provides for that rate under the corresponding option.
Option 2: a fixed annual amount
Instead, the individual can elect to pay each year:
- UI 1,875,000 covering all of the income in scope.
- UI 1,250,000 in tax years in which they meet the more-than-183-day presence test.
- UI 1,250,000 where they make a business investment of more than UI 45,000,000 aimed at expanding productive capacity, subject to the implementing rules.
Spouses of anyone making this election can be brought in by paying 15% of the corresponding fixed amount.
These elections are made annually and can be exercised within the maximum period the law allows — up to twenty tax years after the first election. Given the amounts involved, whether they make sense depends on the size and composition of your foreign income.
Uruguayan residency alone doesn't settle your Argentine position
Buying property and obtaining a Uruguayan tax-residency certificate does not automatically mean Argentina stops treating you as a resident.
Under Argentine law, a person loses residency when they:
- Acquire permanent residency in another country under that country's immigration rules; or
- Absent that, remain abroad continuously for twelve months, subject to the rules governing temporary visits.
The loss takes effect from the first day of the month immediately following the moment the law specifies, and must be documented through ARCA (Argentina's tax authority) procedures.
On top of that, if both countries consider the same person a resident, the Argentina-Uruguay agreement sets out tie-breaker rules to be applied in order:
- Permanent home.
- Center of vital interests.
- Habitual abode.
- Nationality.
- Agreement between the competent authorities.
Sources: Argentine Income Tax Law, articles 117 to 122 and Argentina-Uruguay agreement, articles 9 and 11.
Which is why the following all need reviewing:
- The effective date on which Argentine residency is lost.
- Temporary stays in Argentina.
- The housing available to you in each country.
- Where your family and personal interests are based.
- Any economic activity you keep up in Argentina.
- The filings, deregistrations and appointments required before ARCA.
- Credit for taxes paid in the other country.
A real-estate firm can document the purchase and explain the taxes that come with the transaction itself. The tax-residency outcome calls for coordinated work between Uruguayan and Argentine professionals.
Bienes Personales for as long as you remain an Argentine resident
While you keep your Argentine tax residency, your Uruguayan property generally goes into your Bienes Personales (Argentina's net wealth tax) return.
For tax year 2025:
- The general exempt threshold is $ 384.728.044,57.
- The general scale runs from 0.50% to 1.00%.
- Since tax year 2023, the general scale no longer applies a higher rate simply because the asset sits abroad.
- Reductions are available for taxpayers who qualify as compliant filers.
The tax isn't calculated on the apartment in isolation. It looks at your full set of taxable assets and the valuation rules that apply to each one.
Source: ARCA — Bienes Personales.
We cover this in detail in what taxes an Argentine owner pays on an apartment in Uruguay.
Frequently asked questions
How much do I have to invest to get Uruguayan tax residency in 2026?
It depends which test you're using. One real-estate presumption requires more than UI 3,500,000 plus at least 60 days of presence; another requires more than UI 15,000,000 with no specific day minimum under that provision. There are also the tests based on more than 183 days, principal base of activities, vital or economic interests, and business investment.
Does UI 12,500,000 automatically make me a tax resident?
No. That's the threshold for the real-estate route into the inbound-resident regime, and it's subject to implementing rules. You first have to acquire tax residency on an independent basis.
What is UI 12,500,000 in dollars?
Roughly USD 2,060,000, using the UI value of $ 6.6300 from 8/1/2026 and the BCU dollar rate of $ 40.223 from 7/29/2026. It's a dated conversion, not a fixed dollar threshold.
Can someone who becomes a tax resident in 2026 choose the open-ended 7%?
Not under article 24-Bis. That option belonged to the previous regime and had to be exercised, once only, by December 31, 2025.
Can I get the Tax Holiday without investing USD 2 million?
Yes. The law provides for an annual contribution of UI 625,000 to eligible funds, plus a no-investment route for anyone who meets the more-than-183-day test in each tax year. Both still require satisfying the remaining conditions and, in the case of the funds, watching the implementing rules.
I acquired tax residency before 2026. Do I keep the old regime?
Only if you validly exercised the option within the applicable deadline. Having become a resident before the end of 2025 isn't enough if the election wasn't made by December 31 of that year.
What is the Tax Holiday, and how long does it last from 2026 on?
It's the informal name for the inbound-resident regime. It lets you have certain foreign investment income taxed under IRNR during the year you change residency and the ten years that follow — eleven tax years in total.
If I invest USD 250,000, do I qualify for promoted housing?
The amount isn't a barrier, but it isn't enough to confirm anything either. The unit has to be covered by a promotional declaration, and you need to check the zone, the construction-completion date, the years remaining and the intended use of the lease.
Does being a Uruguayan tax resident get me out of Bienes Personales in Argentina?
Not automatically. You only stop being taxed as an Argentine resident once you lose that status under Argentine law and complete the corresponding formalities. If you end up a resident of both countries, the tie-breaker rules in the bilateral agreement come into play as well.
How we handle this at INGAR
- We keep the purchase separate from the residency analysis. A property can be a sound investment even if it doesn't open the real-estate route under article 24-Bis.
- We verify the specific unit. Before you reserve, we identify the promoted-housing declaration, the construction-completion date and which benefits may still be available.
- We never present an exemption as automatic. We review the zone, the percentage, the remaining term, the intended use and the terms of the lease.
- We coordinate with independent professionals. The escribano (Uruguayan notary) legally represents the buyer, and the residency analysis is handled with tax advisors in both Uruguay and Argentina.
Keep reading
- What taxes an Argentine owner pays on an apartment in Uruguay
- Argentina scrapped income tax on rentals: does Uruguay still make sense?
- Does buying property get you residency in Uruguay?
- Legal residency, tax residency and citizenship: three different things
- Promoted housing (Ley 18.795): the tax benefits
- How much income you need for legal residency in Uruguay
Sources
- IMPO — Ley 20.446, article 648
- IMPO — Title 7 of the 2023 Consolidated Tax Code
- IMPO — Decreto 148/007, article 5-Bis
- DGI — Grounds for tax residency
- IMPO — Decreto 95/026
- IMPO — Resolución DGI 1517/026
- INE — Unidad Indexada, July 2026
- BCU — Exchange rates
- IMPO — Ley 18.795 on promoted housing
- IMPO — Decreto 355/011
- ANV — Implementing regulations for Ley 18.795
- DGI — Tax Ruling 6414
- 2025-2029 Five-Year Housing and Habitat Plan
- Argentina — Income Tax Law, consolidated text
- Argentina and Uruguay — Information-exchange agreement and method for avoiding double taxation
- ARCA — Bienes Personales, rates
Rules and values verified as of August 1, 2026. Dollar conversions are approximate. The article 24-Bis investment routes depend on implementing regulations and should be confirmed before any deal is structured. This article is not a substitute for tax, accounting, immigration or notarial advice.