By Resolution N° 2683/2013 (dated August 27,2013) the percentages fixed by Resolution N° 891/2008 were modified in which concerns to the determination of the income of Uruguayan source for certain operations related to the athlete´s rights.
In this sense, the Resolution establishes an optional and simplified regime for the determination of the income of Uruguayan source, corresponding to: i) operations of rental, use, assignment of use, transfer of federative rights, image rights and similar rights pertaining to athletes; ii) intercession/assistance with respect to the referred activities. The regime applies for the operations partially performed in Uruguay, when such operations are not under the legal provisions which consider that the whole income is Uruguayan.
In this regard, it is considered of Uruguayan source:
if the income´s beneficiary is a taxpayer of the Corporate Income Tax (IRAE): 35,16% of the operation´s gross profit (the percentage under the Resolution N° 891/2008 was 11,71875%)
if the income´s beneficiary is a taxpayer of the Non-Resident Income Tax (IRNR): 93,75% of the operation´s gross profit (the percentage under the Resolution N° 891/2008 was 31,25%).
