Sociedad Anonima Financiera de Inversion (S.A.F.I.)

The law of Uruguay provides for the establishing of companies in this country of various organizational and legal forms, including a financial investment joint-stock corporation, Sociedad Anonima Financiera de Inversion (S.A.F.I.), which may be of practical interest to foreign investors in terms of international tax planning.

If the corporation carries out all business activities, including management, holding meetings, etc., outside Uruguay, S.A.F.I. receives the preferential tax status of an offshore corporation, which is characterized as follows:

* minimum number of shareholders is 2, and their maximum number is not limited.
* minimum registered capital is US$30 000 (or the equivalent in another freely convertible currency). The capital is not required to be fully subscribed and paid upon the establishing of the enterprise;
* the corporation is of a closed type and its shares may not be offered to third parties for free subscription or to the public;
* registered shares and bearer shares of various classes, with or without voting rights, may be issued;
* the corporation is required to maintain a shareholders' register, including records of holders of bearer share certificates;
* the corporation may be managed by one director (physical or legal person, resident or non-resident of Uruguay);
* corporate directors and shareholders data is specified in an open register and must be published in the official bulletin of Uruguay;
* copies of all minutes as well as of annual financial statements are kept at the corporation's registered office in Uruguay;
* the corporation is required to undergo an annual audit, and financial and tax statements are published in the official bulletin of Uruguay.

Offshore corporation (S.A.F.I.) is not subject to taxation in Uruguay, except for capital tax to be calculated according to a very confusing formula, but generally speaking, it is 0.4% of the arithmetic sum of the company's registered capital and free assets as at the time of tax calculation.

Uruguay has free economic zones that provide significant tax advantages to companies registered there, thereby reducing the tax burden to zero.

Typical companies in Uruguay are subject to income tax at a rate of 30%.

Uruguay Double Taxation Agreements

Belgium, Chile, Ecuador, Finland, Germany, Hungary, India, Italy, Japan,     Korea, Liechtenstein, Luxembourg, Malta, Mexico, Paraguay, Portugal, Romania, Singapore, Spain, Switzerland, United Arab Emirates, United Kingdom, Vietnam.

 99 classical offshore, onshore and midshore jurisdictions of Europe, America, Middle East, Asia, Africa and Oceania