No tax treaty between France and Uruguay: what this means for you

The official list of French tax treaties, published in the BOFiP (Official Bulletin of Public Finances), contains no entry for Uruguay. The Uruguayan tax authority (DGI) publishes 25 treaties in force, none of which include France. However, the two countries have an information exchange agreement, which entered into force on December 31, 2010. In practice, each country's domestic law applies: no reduced tax rate is provided for by any treaty, no tax credit is available in France for taxes paid in Uruguay, and no treaty rules exist to differentiate between two residences. This page does not provide information on Uruguayan withholding taxes, as we were unable to obtain this data from an official source.

What the official lists say

The pages read refer to the 2010 agreement as an information exchange agreement. They do not detail its content. Uruguay is not among the 11 states on the French list of non-cooperative states and territories included in this same annex (decree of 15/04/2026).

Two possible residences, no clause to decide between them

Under French law, the BOFiP (Official Bulletin of Public Finances) identifies three categories of criteria for French tax residence: personal, professional, and economic. Only one is required. The BOFiP clarifies that the six-month period is not an absolute criterion: a stay of less than six months in France does not exempt you from tax liability if one of these criteria is met.

On the Uruguayan side, the DGI's guide on the tax residency certificate (dated December 12, 2023) indicates that an individual's tax residency can be established according to the following criteria: more than 183 days in the calendar year, the principal place of business or base of activities, the base of economic interests, and the center of vital interests. The guide does not specify whether only one of these criteria is sufficient. A French criterion and a Uruguayan criterion can be met in the same year.

When a tax treaty exists, it determines eligibility. The BOFiP (French Official Tax Bulletin) indicates that the treaty's definition of resident takes precedence over domestic tax domicile, then, in this order, considers permanent home, closest personal and economic ties, habitual residence, and nationality. This mechanism does not apply here: have your situation reviewed before setting a departure date.

What France does with your Uruguayan income

If you remain a resident of France, the 2026 income tax guide is straightforward: in the absence of a tax treaty, income is taxable in France, without any elimination of potential double taxation. The instructions for form 2047 (income tax return for 2025), specifically the section on investment income, clarify that income originating in a country without a treaty does not entitle you to any tax credit. This income must be declared net of any foreign tax withheld, or gross if no tax has been withheld.

These texts do not specify how much Uruguay collects. This point still needs to be verified with a local professional.

What France considers important if you reside in Uruguay

A non-resident is taxable in France only on their French-source income, subject to any applicable tax treaties. No such treaty applies here.

Exit tax: a reprieve that raises questions

The exit tax applies to taxpayers who have been tax residents of France for at least six of the ten years preceding the transfer, and who hold at least 50% of the profits of a company or securities with a total value exceeding €800,000 according to the explanatory note, or "at least €800,000" according to the tax authority's information sheet. The two texts do not define the threshold in the same way: if your securities are close to this amount, have your file reviewed. Income tax is 12.8%, and social security contributions are 17.2% for a transfer in 2025 and 18.6% for a departure in 2026.

Payment deferral is automatic for European Union member states and for a list of 70 states published in the 2074-ETD notice for 2025 transfers; this case, number 1 in the notice, also applies to states that have concluded a mutual assistance agreement with France regarding tax recovery. Uruguay is not on this list. For states not covered by this case, the notice provides for a deferral upon express request: a representative established in France, security offered to the non-resident tax office for 12.8% of the total capital gains and receivables, and a 2074-ETD declaration filed before the transfer. Review the notice for your year of departure: the list may change.

Accounts opened in Uruguay

A taxpayer domiciled in France must declare annually any accounts and contracts opened, held, used, or closed abroad (forms 3916 or 3916-bis). The penalty is €1,500 per undeclared account. The tax authorities mention an amount of €10,000 for an account located in a country that has not signed a tax treaty with France to combat tax fraud and evasion. The texts consulted do not clarify whether the information exchange agreement with Uruguay excludes this amount: check it before filing your declaration.

French dividend of €10,000 paid to a Uruguayan resident: numerical example (fictitious profile)

Situation. A Frenchman, a fictitious profile, moves to Uruguay and is no longer a tax resident of France. He retains shares in a French company, which pays him €10,000 in dividends.

Issue. He wonders if a treaty reduces French restraint. There isn't one.

Strategy. He applies the withholding of 12.80 % from the "My dividends" page, checking that Uruguay is not on the list of 11 non-cooperative states.

Result. Withholding tax: €1,280.00. Net dividend: €8,720.00. No agreement provides for a more favorable rate. The page does not specify how Uruguay treats this dividend, a point we were unable to find. The amounts are fictitious.

What changes depending on your situation

• Your address: a French or Uruguayan criterion met, and the date of your departure.
• The nature of your income: dividends, salaries, rents, capital gains.
• The value of your securities, if you hold a company: exit tax, deferral, tax relief after 2 years (total value less than 2.57 million euros) or 5 years.
• Your foreign accounts and their declaration.
• Uruguayan law, which this page does not cover: have it validated by a local professional.

The rule depends on your situation. No results are guaranteed.