Tax fraud in Uruguay: penalties, DGI audits and how to fix mistakes

Last reviewed: November 2026 · Reviewed by Stéphane Gombauld, tax expert, technologist and digital nomad

You live in Uruguay or run a business there, and you want to know where an honest mistake ends and fraud begins. After reading, you will know each penalty in the Tax Code, how far back the tax office can go, what changed in 2026, and how to correct an error cheaply.

Uruguay tax fraud regulations in 2026: the key figures

What changed for 2026

• Lower money-laundering threshold. Law 20.469, promulgated on 19 March 2026, rewrote art. 34 of the anti-money-laundering Law 19.574. Tax fraud now counts as a predicate offence once the tax evaded in any fiscal year exceeds 400,000 UI. No threshold applies when false invoices or other false documents were used. The original 2017 text set 1,000,000 UI for years from 2019.
• Prosecution without a DGI complaint in those cases. Under the new wording, such fraud "podrá perseguirse de oficio", meaning prosecutors can act on their own initiative.
• New 2026 fine amounts. Decree 344/025 sets the 2026 contravention range at UYU 680 to UYU 13,220.
• Wider reporting of foreign income. From 1 January 2026, residents pay IRPF on more foreign capital income and gains, under Law 20.446. More foreign data now matters to your Uruguayan return.

Is this guide for you?

Read on if you…

• are a Uruguayan tax resident with income, accounts or property in several countries;
• sign returns for a Uruguayan company, SAS or sole proprietorship;
• found an error in a past return and want to know your exposure.

Probably not your case if you…

• have no income, assets or company in Uruguay;
• want the general rates first. Start with the Uruguay tax landscape overview.

What counts as tax fraud in Uruguay?

Art. 93 of the Tax Code lists the types of infraction. They differ by intent and by what went wrong. Here is the ladder, from mildest to most serious.

Late payment (mora)

Mora is simply paying after the due date. Art. 94 sets a fine of 5% if you pay within five working days. It rises to 10% up to 90 calendar days, and 20% after that. A payment plan requested on time carries a 10% fine.

On top comes a surcharge (recargo) that accrues daily, like interest. The Executive sets it, within a cap linked to Central Bank lending rates. Good payers with a year's clean record may be excused if they pay within the same month.

Formal breaches (contravención)

A contravención is breaking a formal duty: filing late, not registering, or obstructing an audit. Art. 95 sets a fixed fine, updated each year by the Executive under art. 99. For 2026 the range is UYU 680 to UYU 13,220.

Underpayment (omisión de pago)

Omisión is any act or failure that reduces the tax paid, without proven fraud. Think of a wrong deduction or forgotten income. Art. 97 sets a fine of 1 to 5 times the tax omitted. This is the box most honest mistakes fall into when the DGI finds them first.

Administrative fraud (defraudación)

Defraudación is a deliberate act to gain an undue tax benefit. Art. 96 fines it at 1 to 15 times the tax evaded. The DGI must justify the amount case by case.

Here's the catch: the law presumes intent, unless you prove otherwise, in nine listed situations. One is a clear contradiction between your returns and your supporting documents. Another is keeping withheld tax instead of paying it over.

The crime of tax fraud

Art. 110 punishes anyone who uses deception to obtain an undue benefit at the expense of the State's tax revenue. The penalty is six months of prison to six years of penitentiary. As a rule, prosecution needs a complaint by the tax authority, based on a reasoned resolution.

The money-laundering exception changes that for larger cases, as explained above. Fines are cumulative too: art. 101 says sanctions and surcharges in this chapter add up.

How does the DGI detect undeclared income?

The DGI (Dirección General Impositiva, the tax authority) cross-checks several data streams.

1. Bank reporting. Under arts. 1 and 2 of Law 19.484, local financial institutions report accounts of foreign residents and of Uruguayan residents every year. Bank secrecy cannot be invoked against the DGI (art. 16).
2. Exchange with other countries. Art. 15 lets the DGI share this data with foreign authorities under international agreements.
3. Beneficial ownership register. Companies declare owners holding at least 15% of capital or votes to the Central Bank (BCU) register.
4. Third-party data. Invoices, withholdings and payments made by your clients and payers can be matched against your own returns.

If you use the new-resident regime for foreign income, keep proof of eligibility for every year. The tax incentives guide explains the conditions.

How long can the tax office go back?

Art. 38 sets a limitation period of five years. It runs from the end of the calendar year of the taxable event. For annual income taxes, that event is the close of the fiscal year.

The period becomes ten years if you committed fraud, did not register, did not report the taxable event, or did not file returns. Fines and surcharges generally follow the same period as the tax. Contravention fines are the exception: they always prescribe after five years. Practical rule: keep invoices, statements and returns for ten years if anything is unusual.

Who is personally liable?

Art. 21 makes legal and voluntary representatives jointly liable for their principal's taxes when they fail to act with due diligence. Liability is limited to the assets they manage, unless they acted with dolo (intent).

If you are the legal representative of a Uruguayan SAS or SRL, that means you. Running it remotely does not remove the duty. The legal forms of business in Uruguay guide explains who represents each structure.

Beneficial-ownership breaches are costly too. Art. 32 of Law 19.484 sets fines of up to 100 times the maximum contravention fine. At the 2026 maximum, that is up to UYU 1,322,000. Concealing a beneficial owner can cost up to 1,000 times that figure (art. 35).

How do you fix a mistake before it becomes fraud?

Good news: coming forward on your own counts in your favour. Art. 100 lists "spontaneous disclosure with regularisation of the debt" as a factor when grading sanctions. A filing prompted by an inspection the DGI carried out or ordered does not count.

1. Map the error. List the years, taxes and amounts involved.
2. File corrected returns through the DGI online services.
3. Pay the tax with the mora fine and surcharges. Paying within 90 days of the due date keeps the fine at 10% or less.
4. Ask for a payment plan if needed. A plan requested on time carries a 10% fine.
5. Keep evidence of how the error happened, to rebut any presumption of intent.

The Tax Code does not fix a percentage discount for disclosure. The final sanction depends on how the DGI weighs all the art. 100 factors.

Common mistakes (and what they cost)

• Assuming foreign income stays outside Uruguay → since 2026 more foreign capital income is taxable, so silence can become omisión at 1 to 5 times the tax.
• Missing the annual proof for the new-resident regime → you lose the benefit for that year and owe IRPF on foreign capital income.
• Contradictions between returns and books → the law presumes intent, opening the 1 to 15 times fraud fine.
• Ignoring formal duties → contravention fines of up to UYU 13,220 per breach in 2026, and they add up.
• Signing as legal representative without checking → joint liability for the company's taxes if you did not act with due diligence.

Frequently asked questions

Is tax evasion a crime in Uruguay?

Yes. Art. 110 of the Tax Code punishes deceiving the State to obtain an undue tax benefit with six months to six years in prison. Prosecution usually needs a DGI complaint. Since Law 20.469, fraud above 400,000 UI of tax in a year can also be prosecuted directly as a money-laundering predicate. Honest errors are administrative, not criminal.

What is the fine for paying taxes late in Uruguay?

Under art. 94 of the Tax Code, the fine is 5% if you pay within five working days. It is 10% up to 90 calendar days late, and 20% after that. A daily surcharge set by the Executive is added. A payment plan requested on time carries a 10% fine.

How many years back can the DGI audit me?

Five years, counted from the end of the calendar year of the taxable event. For annual income taxes, that is the close of the fiscal year. The period extends to ten years for fraud, failing to register, failing to report the taxable event, or not filing returns.

What is the difference between omisión and defraudación?

Omisión is any underpayment without proven fraud, fined at 1 to 5 times the tax. Defraudación requires a deliberate act to obtain an undue benefit, fined at 1 to 15 times the tax. In nine listed situations the law presumes intent, so you must prove good faith.

Does Uruguay share bank information with other countries?

Yes. Law 19.484 requires Uruguayan financial institutions to report accounts of foreign residents and of local residents to the DGI each year. Article 15 allows the DGI to exchange that data with foreign tax authorities under international agreements. Bank secrecy cannot be invoked against the DGI.

Can I correct a past tax return in Uruguay?

Yes. File the corrected return and pay the tax with the mora fine and surcharges. Under art. 100 of the Tax Code, spontaneous disclosure with payment counts in your favour when sanctions are graded. It does not count if a DGI inspection prompted the filing.

Related guides

• Uruguay tax landscape overview
• Tax residency in Uruguay: the legal tests
• Corporate income tax (IRAE) in Uruguay
• Tax incentives for expats and digital nomads in Uruguay
• Tax fraud regulations of Paraguay
• Tax fraud regulations of Brazil
• All country tax guides

Sources

• Código Tributario, arts. 21, 38, 94–97, 100, 110 – IMPO
• Law 19.574, art. 34 (predicate offences) – IMPO
• Law 20.469 (2026 anti-money-laundering reform) – IMPO
• Law 19.484 on fiscal transparency – Parliament of Uruguay
• Multa por contravención 2026 – Dirección General Impositiva
• Contravención por presentación fuera de plazo 2026 – Dirección General Impositiva

This guide is general information, not personalised tax advice. See how we research and review.