ICOSA: the tax a corporation pays just for existing

When we think about a company's taxes we usually think of IRAE, VAT or Wealth Tax. But corporations (sociedades anónimas, S.A.) also have a tax almost nobody names: ICOSA, the Control Tax on Corporations. It's a 'control' levy: you pay it when you create the S.A. and then every year, simply for existing as an S.A. Here's who pays it, when and how much, in plain language.

What is ICOSA and who pays it?

ICOSA is paid by corporations (sociedades anónimas). It doesn't replace other taxes: it's on top of IRAE (income), VAT and the Wealth Tax; an S.A. may owe all of them. It doesn't depend on the company making money or even having activity: it's owed for having the legal form of an S.A. Mind the acronyms: ICOSA is for the classic 'anónimas'; a SAS (simplified stock company) is a different form and, as a rule, is not reached by ICOSA. If unsure about your case, confirm with DGI or your accountant.

It's paid at two moments

The tax has two taxable events — two moments that trigger it. The first is when the company is born. The decree that regulates ICOSA puts it like this:

First taxable event — Decree 450/002, article 2, literal a):

«La constitución de sociedades anónimas, incluso en aquellos casos en que sea consecuencia de transformación, fusión o escisión.»

In English: The constitution of corporations, even in cases where it results from transformation, merger or spin-off.

The second moment is the close of each fiscal year, whether or not there was activity. Same article, literal b):

«El cierre de cada ejercicio fiscal, independientemente de que la sociedad haya tenido o no actividad.»

In English: The close of each fiscal year, regardless of whether the company had activity or not.

How much is it? A fixed amount that's updated

ICOSA isn't a percentage of your sales: it's a fixed amount calculated on a reference minimum capital. There's a larger amount at incorporation and an annual amount for the fiscal-year close, which in practice is paid in monthly advances. Since that amount is adjusted periodically (set by the Executive, with DGI publishing the current values), it makes no sense to pin a peso figure here that would go stale: always check the year's value at DGI before paying.

Good news: it's an advance on the Wealth Tax

The annual ICOSA isn't always 'lost' money. The rule lets you credit the fiscal-year-close ICOSA against the Wealth Tax (Impuesto al Patrimonio) determined at the same date:

Decree 450/002, article 7:

«El impuesto correspondiente a los hechos generadores referidos en el literal b) del artículo 2°, podrá imputarse al pago del Impuesto al Patrimonio determinado a la misma fecha.»

In English: The tax corresponding to the taxable events referred to in literal b) of article 2 may be credited toward the payment of the Wealth Tax determined at the same date.

In plain terms: if your S.A. owes Wealth Tax, the annual ICOSA you already paid counts as an advance on it. If there isn't enough Wealth Tax, the ICOSA still stands as the cost of keeping the S.A.

Is an S.A. worth it? Think before choosing the form

ICOSA is one reason an S.A. carries a higher fixed annual cost than other forms. A sole trader (unipersonal) or a monotributista pays no ICOSA; a SAS, as a rule, doesn't either. If you're choosing how to formalize, add this cost to the comparison: an S.A. gives anonymity and structure, but drags this tax every year, profits or not. Compare the forms before deciding.

• Taxes in Uruguay by your business form
• The SAS in Uruguay, explained simply

Frequently asked questions

• Who pays ICOSA? Corporations (sociedades anónimas, S.A.), simply for being one.
• Does a SAS pay ICOSA? As a rule, no; it's a different legal form. Confirm your case with DGI.
• Is it owed even with no activity? Yes: the fiscal-year close triggers the tax anyway.
• Is it instead of IRAE or Wealth Tax? No: it's additional. The annual ICOSA can be credited against the Wealth Tax.
• How much is it in pesos today? It's a fixed amount that's updated; check the current value at DGI before paying.
• Does a sole trader pay ICOSA? No. ICOSA is only for corporations.

In short: ICOSA is the annual 'toll' of being a corporation in Uruguay. You pay it when you set up the S.A. and at each fiscal-year close; it's a fixed amount DGI updates, and the annual part can be credited against the Wealth Tax. If you're about to open a company, weigh it when choosing the legal form; and if you already have an S.A., confirm the year's value with DGI or your accountant.