Uruguay provides an IRAE exemption for qualifying software production and related services, but “create a SAS and pay 0% IRAE” is not a valid general rule.
Entity is only the first filter
Article 161 bis restricts the subjective scope to specified IRAE entities. The legal form can therefore matter, but the activity and requirements still need to qualify.
Qualifying activity
The rules cover defined software-production activities and specified related services. Contracts, invoices and actual delivery should describe what the company really does.
Substance and traceability
The regime includes documentation and cost-traceability requirements. Certain software-asset income also uses a qualifying-expense mechanism, making reliable development records important.
Form 3011
DGI lists Form 3011 as the annual information return for software production/development, related services and R&D, including taxpayers seeking the relevant IRAE exemption.
Checklist
- Eligible entity.
- Qualifying activity.
- Consistent contracts and invoices.
- Identifiable development personnel and costs.
- Cost traceability.
- Software registration where applicable.
- Form 3011 and other required returns.
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