BDO URUGUAY URUGUAY A PLACE TO INVEST. BDO Estudio Héctor Defféminis BDO Auditores y Consultores S.R.L.

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1 BDO URUGUAY URUGUAY A PLACE TO INVEST BDO Estudio Héctor Defféminis BDO Auditores y Consultores S.R.L.

2 INDEX 1. URUGUAY AS A PLACE TO INVEST 2. BDO URUGUAY 3. OUR INTERNATIONAL CLIENTS 4. ADVANTAGES OF INVESTING IN URUGUAY 4.1 TERRITORIALITY PRINCIPLE 4.2 INDUSTRIAL AND COMMERCIAL ACTIVITY IN URUGUAY 4.3 FREE TRADE ZONES IN URUGUAY 4.4 TRADING ACIVITIES 4.5 URUGUAYAN COMPANIES AS HOLDING ENTITIES

3 1. URUGUAY AS A PLACE TO INVEST Following, an Official Presentation from the Public Entity, URUGUAY XXI

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38 2. BDO URUGUAY

39 2.BDO URUGUAY Services The Firm Estudio Hector Defféminis" was founded in In 1985 joined the international Network becoming a BDO Memeber Firm. Total staff: 70 people Audit Tax Advisory Business Consulting Outsourcing Internal Audit and Processes Human Resources Human Capital

40 3. ADVANTAGES OF INVESTING IN URUGUAY

41 3. ADVANTAGES OF INVESTING IN URUGUAY 3.1 TERRITORIALITY PRINCIPLE GENERAL TAX SYSTEM: CORPORATION INCOME TAX 25% INCOME TAX ON NON RESIDENTS (IRNR) 7% CPITAL TAX 1,5% VALUE ADDED TAX- VAT (IVA) 22% Government returns to exporters between 2% and 4% over their exports. The tax regime in Uruguay is based on the principle of territoriality. Consequently, taxes that comprehend our tax system only levies activities performed in Uruguayan territory and assets economically located or used in the country economically. A Uruguayan Company is subject to the exposed general tax regime. While the company carries out all its activities abroad and keeps its assets outside the country, it will not have to pay these taxes in Uruguay.

42 3.2 INDUSTRIAL AND COMMERCIAL ACTIVITIES IN URUGUAY GENERAL OVERVIEW Local and foreign investors are treated equaly. Investments do not need previous authorization or registration. Free transfer of capital and profits of foreign investments Bank and Tax secrecy only vulnerable by Court Order. Access of uruguayan products/merchandise to Mercosur without import tarifs. Temporary admision of import free of tax, of foreig goods to be re-exported, either as they were imported or after being subject to certain added value with effecctive occupation of skilled manpower. Relatively low labor costs. Companies save between 20% and 30% of labor cost

43 3.2 INDUSTRIAL AND COMMERCIAL ACTIVITIES IN URUGUAY INVESTMENTS EXCEMPTIONS Exemption from Income Tax of between 20% and 100% AMOUNT of the investment and for a minimum of 3 years according to the project's contribution to: The increase in employment Increase in exports Decentralization Use of cleaner technologies ExceMption of Capital Tax on civil works for 8 years in Montevideo and 10 years in the rest of the uruguayan territory and on movable throughout their USEFUL lives. Exemption from taxes or duties on imports of movable fixed assets, declared uncompetitive to domestic industry. Return of the 100% of the value added tax (VAT), including IN local purchases of materials and services for civil works.

44 3.2 INDUSTRIAL AND COMMERCIAL ACTIVITIES IN URUGUAY Corporate Income Tax Excemption Practical Example Investment in Uruguay U$S Employment Decentralization Increase in exports Cleaner production or investment in R & D 30 employees Outside Montevideo U$S annual U$S of total investment Exception on Corporate Income Tax 33% Direct reimbursement of Income Tax U$S

45 3.3 FREE TRADE ZONES IN URUGUAY 100% of users exempt from: Corporation Income Tax(IRAE). Capital Tax. Import Duties. Any other created or to be created tax. All kinds of activities can be developed in the Free Trade Zones: industrial, commercial or services. The Business Parks focused in technology and services operating in Montevideo are: Aguada Park Zonamerica Parque de las Ciencias WTC Free Zone Free movement and repatriation of capital.

46 FREE TRADE ZONES IN URUGUAY Business Platforms Logistic and Distribution Financial Services Headquarters Shared Services Centers Consultancy and Professional Services Software Call Centers Biotechnology

47 FREE TRADE ZONES IN URUGUAY PRACTICAL EXAMPLE FINAL CLIENT IT SERVICE (software) Foreign Company (Sede Category) IT SERVICE (software) Uruguayan Company operating in Free Trade Zone (Subsidiary) IN URUGUAY: Exception: Income Tax on Non Residents (IRNR) Exception: Corporation Income Tax (IRAE). Capital Tax.

48 3.4 TRADING ACTIVITIES IN URUGUAY Objective: To mediate through a common Uruguayan corporation (S.A.U) export sales to several final customers (importers). Merchandise is shipped directly to the end customer (importer) by the exporter and does not physically circulate in Uruguayan territory. Tax regime for Trading Operations - IRAE: 0,75 % of operation s gross profits - IRNR withhold dividends: 0,15 % of operation s gross profits - Tax Equity: mot meaningful Profits from the uruguayan S.A.U. are freely available, they can be transfered overseas at any time and have no restrictions or require administrative registration after the respective IRNR withhloldings have been made. S.A.U.s can collect and make payments of these invoices in banks located in Uruguay or in another jurisdictions. The Uruguayan financial system guarantees by law, the banking secrecy and the capital s freecirculation. The proposed scheme also applies to intermediation services.

49 TRADING ACTIVITIES IN URUGUAY Practical Example U$S Sale of goods CPV ( ) Gross Margin Taxed amount (3% o/gross margin) Corporation Incoma Tax Rate 25% Corporation Income Tax amount Amount taxed for distribution of dividends IRNR rate for distribuion of dividends 7% IRNR on distribution of dividends Total taxes on the sale operation of U$S

50 3.5 URUGUAYAN COMPANIES AS HOLDING ENTITIES Applying the principle of territoriality, activities developed outside Uruguayan territory and the establishment of overseas investments, are not subject to taxation in the country. Main uses Ownership of shares in other companies in foreign jurisdictions. Ownership of real Estates abroad. Investments in foreign markets. Holding Assets

51 CONTACT INFORMATION BDO URUGUAY BDO Estudio Héctor Defféminis BDO Auditores y Consultores S.R.L. Web: BDO INTERNATIONAL Rincón 487-8º and 11º floors C.P Montevideo - Uruguay Ph.: (598) / (598) (*) Fax: (598)

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