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Decreto 329/025 is the most comprehensive revision of Uruguay's general investment-promotion architecture in five years, updating the Ley Nº 16.906 (1998) regulatory framework administered by COMAP. The decree replaces Decreto 268/020 and introduces eight structurally significant changes:
1. Extended project timeline. The window for computable investments expands from 4 to 5 years from the date of project presentation to COMAP, with the addition of a 6-month prior-investment admission window (capped at 20% of the eligible total). This materially reduces the risk of large capital-intensive projects missing the eligibility window due to procurement lead times.
2. "Large investment" (gran inversión) category. Projects exceeding UI 180 million (~USD 25 million at current exchange rates) qualify for the gran inversión tier with a 10-year computable-investment timeline and enhanced IRAE exemption tiers above the standard formula.
3. "Mega-investment" tier. Projects above UI 300 million qualify for a 100% IRAE exemption over 24–25 years, subject to minimum thresholds for employment creation, the I+ (innovation-and-investment) indicator, and decentralisation commitments. This tier targets transformative single-site projects — greenfield data-center campuses, industrial-scale green-hydrogen electrolysis facilities, and pulp-mill expansions.
4. SME incentive expansion. Micro and small enterprises receive +15 percentage points of IRAE exemption above the standard tier plus two additional benefit years; medium enterprises receive +10 points plus one year.
5. Maintained fiscal package. The decree preserves exemption from the Impuesto al Patrimonio (wealth tax), customs duties on capital goods non-competitive with national industry, and VAT credit certificates for locally purchased inputs, equipment, and services under qualifying projects.
6. Restructured multi-criteria scoring matrix. The project-evaluation matrix is re-weighted to prioritise: decentralisation (projects locating outside the Montevideo metropolitan area receive territorial premiums of 10–15% depending on geographic category); export capacity; employment quality (stable formal employment, above-median wages); innovation and R&D intensity; environmental sustainability and COP-alignment. The rebalancing deliberately shifts the incentive gradient away from large-volume capital investment toward high-quality FDI with greater regional-spillover effects.
7. Strategic-sector calibration. The decree explicitly names eight priority sectors for alignment with Uruguay's national strategy: data-center infrastructure, green hydrogen, sustainable forestry-pulp, agtech, biotech, global business services (GBS/BPO), advanced manufacturing, and circular economy. Projects in these sectors receive additional scoring weight in the matrix.
8. Regulatory stability guarantees. Qualifying investors receive regulatory-stability commitments during their benefit period — addressing Uruguay's historically cited concern that regime changes could strand long-horizon capex commitments. This clause is specifically relevant to the UPM Paso de los Toros successor pipeline, the Google Canelones data-center expansion underway, and prospective green-hydrogen project developers.
Uruguay is a top-three Mercosur+ FDI-per-capita destination and the structural nearshoring counterweight to Mexico/Costa Rica/Paraguay in the LatAm investment-promotion peer-set. Decreto 329/025 is the first comprehensive overhaul of the general investment-promotion regime in five years, bridging the Lacalle Pou → Orsi administration transition. It completes the Mercosur+ modernised investment-incentive peer-set alongside BR Lei 14.789 (PIE), AR Ley 27.742 (RIGI), CL Ley 21.713, and PY Ley 7548/2025 — all of which represent post-2024 structural upgrades to the FDI-incentive architectures of the major Mercosur+ economies.
The mega-investment tier (24–25-year IRAE exemption) is the most material structural development for the data-center and green-hydrogen investment pipeline. The Google Canelones data-center campus, MercadoLibre regional fulfilment infrastructure, and the UPM operational-phase reinvestment cycle are the immediate beneficiaries. On the forestry-pulp axis, the Stora Enso Uruguay pipeline and any prospective UPM successor project are the relevant reference points.
The explicit calibration toward EU CBAM exposure and Mercosur-EU FTA (iTA, provisional application from 1 May 2026) sustainability requirements is structurally significant: the scoring-matrix weighting for environmental sustainability functions as a de facto alignment mechanism between Uruguay's investment-promotion architecture and the EU trade-partner requirements that will govern Mercosur exports under the iTA.
peg regime, and the new mega-investment tier together create the strongest IRAE incentive stack in the Mercosur region for hyperscale data-center capex — Google's expansion at Canelones and any subsequent hyperscaler entry are immediate candidates.
20–25-year project horizon of industrial-scale green-hydrogen electrolysis facilities; Uruguay's wind resource (among the strongest in South America) positions it as a viable Atlantic-corridor green-H₂ export hub if offtake contracts with European buyers materialise under the iTA.
UPM-CMPC-Stora Enso forestry-pulp axis; the innovation/R&D matrix weighting supports agtech clusters linked to INIA (Instituto Nacional de Investigación Agropecuaria) and the global precision-agriculture pipeline.
FDI-incentive benefits beyond the mega-project layer; its effectiveness depends on COMAP processing capacity and the uptake rate among non-Montevideo SMEs (a structural weakness of Decreto 268/020).
the sector-alignment weighting relative to the decree text?
pipeline-ready green-hydrogen or data-center project in the 2026–2027 planning horizon large enough to trigger the UI 300 million threshold (~USD 42 million)?
administrative capacity and decision-processing timelines for projects spanning the cutover?