Montevideo – Uruguay www.estudiorda.com Good morning/afternoon everybody. It’s a pleasure to be here with you. Now we would like to give a brief presentation of our firm and country. Montevideo – Uruguay www.estudiorda.com 1

real estate (urban and rural) Estudio RDA is a medium-sized traditional law firm that basically provides legal services to markets in Latin America and Europe and which in the last 30 years has specialized in tax planning. Our main services are: legal advising accounting notarial auditing outsourcing fiduciary real estate (urban and rural) Our firm is formed by lawyers, accountants and notaries who pride themselves on the professionalism of their work. Our firm offers the best tax-planning solution according to the needs of our clients, complying with all international regulations on due diligence and anti-money laundering. We also provide advice on agribusiness and real estate investments

GEOGRAPHICAL LOCATION URUGUAY Uruguay was a Spanish colony and has been an independent country for 180 years. The country has a solid legal system which provides stability. Our main source of income is from agricultural, cattle farming, dairy and forestation activitites.      Tourism, as well as financial, logistic and IT services are also very important.  Uruguay is located in the southeastern part of South America. The country is bounded in the east by the Atlantic Ocean with 650 km of coastline. Uruguay is well known for its natural resources, vast prairies, wildlife and rich multicultural history.

FACTS ABOUT URUGUAY Independent since 1830 Capital: Montevideo Area: 177,000 km2 Population:3,300,000 (2011) Language: Spanish Government: Democratic Representative Republic Literacy:98.3% GDP per capita – USD 15,000 Here you can see some facts about our country as the area, population, language etc.. Uruguay is the smallest country in Southamerica in terms of size and population.      100%of its population is of European descent, mainly Spanish, Italian and French.– Since our presentation has to be brief, we will focus on our tax system, corporations, trading operations in Uruguay and Free Trade Zones. For this reason, we will not be able to expand on the country and the possibilities of investments, but you may contact us in case you need additional information.

URUGUAY AS A FISCAL JURISDICTION Territorial source principle Uruguay has adopted the territorial source principle of taxation with certain exceptions. The different taxes levy income from Uruguayan source, i.e, those which derive from activities developed, assets located or rights used economically in Uruguay. Uruguay has never been a tax heaven. Our country has adopted the territorial source principle of taxation offering non-taxation advantages to income and assets located abroad. It is important to bear in mind that Uruguay has never been considered a tax haven. Physical persons residing in Uruguay do not pay taxes on their assets located abroad, nor on the income received from abroad, except on the dividends and financial investments which are subject to a 12% tax rate. 

URUGUAY AS A FISCAL JURISDICTION “Reasonable” rate of taxation Net Income (Legal persons) 25% Dividend distribution 7% Net worth tax 1.5% As you can see our country has a reasonable rate of taxation. Therefore assets, income and dividends from abroad are exempt. Companies pay 1.5% on assets located in Uruguay. Assets located abroad are exempt.    Profits in Uruguay are subject to 25% and the distribution of dividends to  7% on net income.      Profits from abroad are exempt. Assets, income and dividends outside Uruguay are exempt.

URUGUAY AS A FISCAL JURISDICTION Treaties to avoid double taxation Treaties in force: Germany Hungary Spain Mexico Switzerland Liechtenstein Portugal Treaties pending parliamentary confirmation: Malta South Korea Ecuador India Argentina Tax Information Exchange Treaties: Sweden France This is a list of the treaties that UY has signed which are based on the OECD model. In addition, there are technical negotiations being conducted with about 12 countries. Faroe Island, Denmark, Island, Norway, Belgium, Finland, Canada, Australia, Greenland, Malasya, Netherlands, United Kingdom, Romania and Italy.

URUGUAYAN CORPORATIONS (ON SHORE) Governed by Act N°16. 060 of Jan TAXES The Uruguayan taxation system is governed by the principle of territorial source, thus levying taxes only on activities carried out in the country. GENERAL CHARACTERISTICS Scope: Uruguay and abroad. Shares: Bearer and registered shares. Board of Directors: can be formed by a single director, either a physical or legal person, resident or non-resident. Agents: appointed by the Board of Directors and may be revoked at any time.   Shareholders: there can be a single shareholder, whether a physical or legal person, resident or non-resident Here you can see a general description of on shore corporations. And the important aspect is that off shore corporations were eliminated in 2007 to comply with OECD regulations. Companies pay 1.5% on assets located in Uruguay. Assets located abroad are exempt.    Profits in Uruguay are subject to 25% and the distribution of dividends to  % on net income.      Profits from aborad are exempt.

TRADING OPERATIONS DIAGRAM COUNTRY A EXPORTER COUNTRY B PURCHASER (Country of destination) Goods, securities or services According to the law, trading operations can be carried out for goods, services and securities located or used outside Uruguay. Only 3% of the profits is considered from Uruguayan source for tax purposes and are subject to the regular rate of 25%. This is the usual rate and since it is not a differential rate, it is admitted by tax authorities of different countries and by double taxation treaties.  TRADING COMPANY On Shore – Uruguay In these trading operations Uruguayan companies only pay a rate of 0.75% on net profits and shareholders 0.21% on dividends. Only 3% of profits are taxed at a regular rate of 25%.

OPERATIONS IN AND FROM FREE TRADE ZONES ARE TAX EXEMPT Professional, financial, banking and IT services Storage and Fractioning of goods Trading of goods and services This last slide is about Free Trade zones. Users of Free Trade Zones may be private or public entities and as you can see operations in and from free trade zones are tax exempt. There are 10 free trade zones in Uruguay with the presence of worldwide companies. The predominant activities among these companies are the warehousing of goods and the rendering of services.   

THANK YOU !! Montevideo – Uruguay www.estudiorda.com Good morning/afternoon everybody. It’s a pleasure to be here with you. Now we would like to give a brief presentation of our firm and country. Montevideo – Uruguay www.estudiorda.com 11