Global minimum tax of 15% in Uruguay: what the IMCD is

In 2026 one of the most talked-about international tax changes took effect: the global minimum tax. In Uruguay it's called the Impuesto Mínimo Complementario Doméstico (IMCD). It sounds huge, but it targets a very specific audience. Here's what it is and who it actually affects.

What the IMCD is

The IMCD is an annual tax on the income of entities that make up a large multinational group. It comes from the OECD initiative known as “Pillar Two”, whose goal is for those companies to pay at least a 15% effective rate wherever they operate.

How the 15% rate works

The logic is a “top-up”: if a multinational group has an effective tax rate in Uruguay below 15%, the IMCD charges the difference up to that 15%. This prevents local tax incentives from leaving these companies paying less than the internationally agreed minimum.

Who it reaches (and who it doesn't)

Only very large multinational groups exceeding the revenue thresholds set by the rule. It does not reach SMEs, sole proprietors, monotributistas, or the vast majority of Uruguayan companies. There are also exemptions for entities covered by valid fiscal-stability clauses. The detail is in Title 21:

Why it still matters to you

Even if you don't pay it, it marks a trend: Uruguay is aligning its system with international standards and starting to put limits on certain tax incentives. For anyone weighing where to invest or set up a company, the incentive landscape is shifting.

At a glance

In short: the IMCD ensures a 15% minimum taxation for large multinational groups in Uruguay, without touching SMEs or small taxpayers. It's a fundamental shift in international rules; if your company is that large, check the details with DGI.