DGI Tax Inspections: How to Respond to an Inspection

On October 7, 2026, Uruguay’s General Tax Directorate (Dirección General Impositiva or DGI) announced that, since late September, its inspectors had been conducting nationwide compliance checks. According to the agency, taxpayers are selected based on a risk assessment carried out using information already held by the tax administration.

The inspections focus on two situations: businesses that sell primarily to final consumers and show indications of sales undervaluation (reporting amounts lower than actual sales or failing to document transactions), and businesses that remain under small-business tax regimes despite exceeding the applicable turnover thresholds. In addition, random checks of tax registration and invoicing are carried out independently of the risk assessment.

Depending on the level of risk, the DGI may issue a preventive notice, require the correction of identified discrepancies, or initiate a formal tax audit.

In practice, an inspection often begins at reception or at the counter, where staff may not know what the inspector is entitled to request or what they should agree to sign. What happens during this initial interaction can affect the remainder of the proceedings and, in some cases, the personal assets of directors and representatives.

Preparing in Advance

The DGI cross-checks information from electronic invoicing, withholding and collection agents, sales and purchase reports, the National Customs Directorate, other taxpayers, and tax authorities in other countries. Businesses should therefore verify in advance that their tax returns are consistent with this information.

Corporate and commercial books must also be up to date, as must the information on directors, attorneys-in-fact and registered addresses filed with the DGI; the ultimate beneficial ownership register maintained by the Central Bank of Uruguay (BCU); relevant contracts; and supporting documentation for tax calculations, including accounting and tax reconciliations and reconciliations against electronic tax receipts (Comprobantes Fiscales Electrónicos or CFEs).

Receiving the Inspector

Article 68 of the Tax Code grants the tax administration broad audit and inspection powers. These include requiring the production of books, documents and commercial correspondence; summoning taxpayers and other liable parties; taking custody of documentation; and inspecting movable and immovable property occupied by the business. Article 70 requires taxpayers to cooperate and permit inspections at their business premises, offices, warehouses and means of transport.

Refusing entry or obstructing the inspector’s work constitutes an infringement punishable by a fine under Article 95 of the Tax Code. In addition, an obstructive attitude may prejudice the company’s relationship with the tax administration, justify more stringent measures (such as the seizure of documents or a court-authorized search), and weaken the company’s position in subsequent stages of the proceedings.

The exception is a private residence. Article 68 requires a judicial search warrant to inspect a private home, in accordance with the inviolability of the home established in Article 11 of the Constitution. If a business operates from the owner’s home, the inspector may enter the areas used for business activities, but not the residential areas.

Before allowing entry, the company should request the inspector’s official identification card and record the inspector’s name and identification number. If there is any doubt, the inspector’s identity can be verified by calling the telephone number provided by the DGI (2 1344 6671) before showing or handing over any documentation.

How Far Can the Inspector Go?

The measures taken during an inspection must be proportionate to the matters being investigated. Accordingly, the Tax Code permits the seizure of books and documents only “when the seriousness of the case so requires,” for a maximum period of thirty business days, which may be extended only by judicial order.

If a request appears disproportionate—for example, because it concerns tax periods for which the right to assess tax is time-barred, information unrelated to the taxes under review, or the removal of documents essential to business operations—the company may record its objections in the inspection report, raise them in writing, request a reasonable period of time, or propose alternatives. These may include providing copies instead of originals or making the documents available for inspection at the company’s premises. Furthermore, the company is not required to disclose confidential information that is irrelevant for tax purposes.

The same principle applies to evidence provided by the company: submitting more information than requested may open up lines of investigation unrelated to the scope of the inspection.

Taxpayer Rights

The company has the right to be informed of the inspection from the outset, to submit and challenge evidence, to confidentiality regarding the information it provides, and to legal representation. It is not required to incriminate itself; accordingly, it should avoid making substantive statements without legal advice.

Certain irregularities may result in the nullity of the proceedings. These include entering a private residence without a judicial warrant; seizing documentation protected by professional, banking or commercial secrecy; seizing computers containing personal email accounts; or questioning witnesses without summoning the taxpayer. If any of these circumstances arise, they should be expressly recorded in the inspection report.

The Inspection Report and Subsequent Defence

An inspection report is drawn up at the end of the inspection. Signing it confirms that the procedure took place but does not imply agreement with its contents. Before signing, the company should read the report carefully, record any observations or objections, and request a copy. It is preferable to provide explanations in writing and with legal advice.

If the tax administration considers that an infringement has occurred, Article 46 of the Tax Code provides for preliminary proceedings in which the interested party is given fifteen days to submit a defence and offer evidence. This is the principal opportunity to challenge the facts and the applicable law, and the deadline must not be allowed to expire.

The final administrative decision may be challenged through an application for reconsideration (recurso de revocación) and a hierarchical appeal (recurso jerárquico) within ten business days of notification. Once the administrative remedies have been exhausted, an annulment action may be brought before the Administrative Litigation Tribunal (Tribunal de lo Contencioso Administrativo).

Liability of Shareholders, Directors and Representatives

Under Article 21 of the Tax Code, legal and voluntary representatives who fail to exercise due diligence are jointly and severally liable for the company’s taxes. As a general rule, this liability is limited to the value of the assets they manage or control, unless they have acted fraudulently, and applies only to taxes accrued during their tenure.

The regime is stricter for Corporate Income Tax (Impuesto a las Rentas de las Actividades Económicas or IRAE). Article 95 of Title 4 of the Consolidated Tax Code makes the shareholders of partnerships and the directors of corporate taxpayers jointly and severally liable, even in the absence of fault, without a monetary cap but subject to a temporal limitation. For a director or general manager, tax compliance therefore also represents a personal liability risk.

Practical Recommendations

We recommend appointing and training an internal point of contact to receive inspectors and establishing a clear notification procedure identifying who must be contacted immediately, including company management, the accounting adviser and legal counsel. Reception staff and site managers should be familiar with this protocol.

The company should also keep a record of all documents produced, copied or retained by the inspectors, and consult its legal and accounting advisers whenever questions arise—particularly before acknowledging any infringement or signing a tax settlement agreement.