Transfer Pricing Developments in Uruguay for 2024

June 26, 2024

In 2024, Uruguay continues to strengthen its Transfer Pricing regulatory framework, adapting to international standards and facing new challenges in a globalized economic environment.

Current Regulatory Context

Current Legislation

Uruguay has implemented a series of regulations that align its legislation with OECD guidelines. These regulations seek to ensure that transactions between related companies are carried out at market prices, avoiding the erosion of the tax base and the transfer of profits to jurisdictions with low or no taxation. This legislation stipulates the obligation to file Form 3001, among other documents such as the Transfer Pricing Study, Master File and Country-by-Country Report.

Documentation Requirements

Companies are not required to submit a Transfer Pricing Study justifying intercompany transactions, prepared prior to the filing of the F 3001, but it is submitted only upon request of the DGI.

Challenges and Opportunities

New Demands of the Global Environment

2024 presents new challenges for companies in Uruguay, which must adapt to changes in international regulations and the expectations of local tax authorities. Transparency and consistency in documentation are key to comply with requirements and avoid penalties.

Technology and Automation

Digitization and process automation in Transfer Pricing documentation offer opportunities to improve accuracy and efficiency. Technology tools enable companies to collect and analyze large volumes of data, facilitating compliance.


Transfer Pricing developments in Uruguay for 2024 reflect a continued commitment to transparency and tax fairness. Companies should be attentive to regulatory changes and take advantage of the technological tools available to comply with their obligations and optimize their processes.


For more information on how to manage Transfer Pricing in Uruguay, contact us at TPC Group. We are here to help you navigate the complex regulatory environment and ensure compliance with current regulations.

Source: OECD

Source: Uruguay’s General Tax Directorate (DGI)