Users of free trade zones are, in regards to the activities performed therein, exempt from all national taxes, existing or to be created in the future, even those requiring a specific exemption by law.

They shall be exempt from the following taxes, among others:

Tax on Income from Economic Activity (“IRAE”)

Net Worth Tax (“IP”)

Value Added Tax (“IVA”)

Specific Internal Tax (“IMESI”)

Tax on Control of Corporations (“ICOSA”)

Special contributions to social security (made in the name of Uruguayan employees), and pecuniary compensations determined in favor of non-state legal entities in the field of social security are not included in the abovementioned tax exemptions. Dividends or profits credited or paid to the name of natural or legal persons resident abroad shall not be exempt from the referred taxes to the extent that they are subject to taxes in the country of residence of the person benefited and such country allows for the possibility of tax credits for taxes paid in the Republic of Uruguay.

All goods, services, merchandise and raw materials, regardless of their origin, entering or exiting the free trade zones are exempt from all taxes.

The Uruguayan State, subject to liability for damages, ensures users of free trade zones, for the whole period of duration of the contract, all tax exemptions, benefits and entitlements agreed upon.

OTHER BENEFITS

A special regulatory system for the incorporation of partnerships, including more benefits than the usual regulations, is applicable to companies incorporated as users of free trade zones.

In what concerns the collection of duties by the National Ports Bureau, entries and exits of goods and their transportation from and to free trade zones will be considered as international transit where fees will be charged for only one entry and one exit.

The State monopolies relative to industrial and commercial services are not applicable in free trade zones.

Free trade zones offer the possibility of free entry and exit of currencies, securities and precious metals.

All requirements, existing or to be determined in the future, relative to the mandatory inclusion of national components in goods manufactured do not apply in the case of goods-manufacturing activities carried out in free trade zones. Likewise, all requirements that condition, or might possibly condition, the entry or exit of goods to or from free trade zones are not applicable, with the sole exception of those relative to the control of such goods.

Certificates of origin are issued for all products manufactured in the free trade zones. The preferential treatment given by third countries to exports of certain Uruguayan products, and in cases of limited volumes and values will be applied to the benefit of exporting industries already established in the non-free-trade territory in regards to such products.