PRACTICAL GUIDE                                                                 TO URUGUAY’S                              ...
design: mjf.com.uyIndEXIntroduction.......................................................................31.Executive sum...
INTRODUCTIONUruguayan free trade zones are areas located within national territory that are not part of Uruguay’scustoms t...
1. EXECUTIVE SUMMARY//	 Aguada Park is a free trade zone exclusively for services.1 The companies setting up in AguadaPark...
2. ACTIVITIES	          THAT CAN BE UNDERTAKEN IN AGUADA PARKAll types of service activities may be undertaken in Aguada P...
For the first four services mentioned (international call centers, electronic mailboxes, distancetraining, issuance of ele...
3. TAX ADVANTAGESThe Free Trade Zone Law (No. 15,921) establishes that free trade zone users are exempt fromall current an...
4. OTHER BENEFITSIn addition to tax benefits, other benefits are available to users://	 Government monopolies on utility s...
5. STEPS TO START OPERATINGTo be entitled to the tax benefits mentioned in the foregoing chapter the company must obtainUs...
Once such documentation has been legalized, the process under Uruguayan law for recognition ofthe parent takes from 30 to ...
6. LEGAL SECURITYThe Free Trade Zones Law (No. 15,921) declares the promotion and development of free tradezones to be in ...
7. GOVERNMENT OVERSIGHTFree trade zones are subject to oversight by the Free Trade Zones Area (an agency of theMinistry of...
Regulatory References1. Resolution 486/007, art. 1: “ITSEN S.A is hereby authorized to operate a private free tradezones f...
zone opts out (in writing) of the Uruguayan social security system there shall be no obligationto make the pertinent contr...
16. Law 15,921, art. 2 (as drafted in art. 65 of Law 17,292): “(...) Free trade zone usersmay also provide the following t...
necessarily be provided in the said areas (…).” This criterion was confirmed by the GeneralRevenue Service in various reve...
territory; and (b) that the said goods are brought in under the framework of the said regimendirectly by the manufacturer ...
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  1. 1. PRACTICAL GUIDE TO URUGUAY’S FREE TRADE ZONE SYSTEMThis document has been prepared by Ferrere Abogados to present an overview of the most relevant aspects of Uruguayan Free TradeZone legislation which is frequently of most interest to foreign investors. It does not pretend to analyze in detail any of the laws, decreesor regulations referenced and it does not constitute on its own sufficient basis for making decisions without previously consulting with anattorney. Ferrere assumes no liability for the decisions adopted without prior, direct or specific consultation with our attorneys.Ferrere (Montevideo)Av. Dr. Luis A. de Herrera 1248World Trade Center, Torre BMontevideo | UruguayPhone: (598 2) 623 0000Fax: (598 2) 628 2100Email: ferrere@ferrere.com 1
  2. 2. design: mjf.com.uyIndEXIntroduction.......................................................................31.Executive summary...........................................................42.Activities that can be undertaken in Aguada Park.................53.Tax advantages.................................................................74.Other benefits..................................................................85.Steps to start operating...................................................96.Legal security.................................................................117.Government sight...........................................................12Regulatory references........................................................13 2
  3. 3. INTRODUCTIONUruguayan free trade zones are areas located within national territory that are not part of Uruguay’scustoms territory and which provide broad tax exemptions.The free trade zone legal regimen is set forth in Law No. 15,921 –passed on December 17, 1987– and related amendments, decrees and resolutions.We have created this practical guide to facilitate understanding of the system and to aid companiesin analyzing it. It seeks to respond to the chief concerns that generally arise upon assessing thepossibility of setting up business in a free trade zone.The seven chapters of this guide cover the following aspects:// What activities can be engaged in at Aguada Park? //// What are the tax benefits and the system for social security contributions? //// Are there other tax incentives? //// What steps must be taken to start operating and what types of corporate organizationscan be adopted by users? //// Is it a stable and secure regimen for investors? //// Are companies overseen by government agencies? //The first chapter summarizes the main aspects of the system in five points.As explained in this guide, the Uruguayan system provides for almost absolute tax exemption, whichgoes far beyond the tariff benefits that other free trade zones in the region tend to provide. 3
  4. 4. 1. EXECUTIVE SUMMARY// Aguada Park is a free trade zone exclusively for services.1 The companies setting up in AguadaPark may engage in all types of services provided they are rendered abroad, to other companiesestablished in Aguada Park,2 or to companies established in other Uruguayan free trade zones.3// To operate in Aguada Park it is necessary to become a free trade zone “user”.4 Users mayadopt a variety of corporate forms (for example: corporation, branch, limited liability company),but in all cases the company’s purpose must be limited to providing services within the free tradezone and/or abroad. Additionally, to obtain “user” status it is necessary to sign a user agreementand submit a Business Plan. All of this must be approved by the government agency regulatingand overseeing Free Trade Zones in Uruguay.5 Government agency approval takes approximatelytwo months.// Regardless of the type of company, users are exempt from all national taxes (Economic ActivityIncome Tax, Nonresident Income Tax, Net Worth Tax, Value-Added Tax),6 with the exception ofsocial security contributions7 and taxes on income of the user’s employees.// Activities in Aguada Park have three limitations: (i) companies can only perform services;8(ii) save specifically established exceptions,9 companies cannot provide services or perform anyactivity whatsoever within Uruguayan non-free territory;10 and iii) at least 75% of the company’semployees in Aguada Park must be Uruguayan.11 Noncompliance with any of these requirementsgives rise to sanctions that can imply forfeiture of all tax benefits.12// The State has declared promotion and development of free trade zones in Uruguay to bein the national interest.13 It likewise assures users of Uruguay’s different free trade zonesthe tax exemptions and benefits for the full term of their user agreements, under liability fordamages.14 4
  5. 5. 2. ACTIVITIES THAT CAN BE UNDERTAKEN IN AGUADA PARKAll types of service activities may be undertaken in Aguada Park, provided they are rendered fromthe free trade zone to other companies within Aguada Park, to companies established in otherUruguayan free trade zones, and/or abroad.For example, without limitation, following are some examples of activities that can beperformed:// International outsourcing// Shared services centers// Call centers// Financial services// Professional services// IT services// Distance trainingAs exceptions, Uruguayan rules allow the following services to be provided to Uruguayan non-freeterritory:// International call centers, except those whose sole or main target is non-free national territory15// Electronic mailboxes// Distance training// Issuance of electronic signature certificates16// Services for production of logical supports, IT advice and IT training17// Management, administration, accounting and similar services provided to related entities devoted to provisioning and port logistics services, provided they do not exceed 20% of total income for the year18Beyond these cases, the Executive Branch may authorize other activities that are beneficial tothe national economy or for economic and social integration of States.19The tax exemption of the Free trade zone does not apply to the aforesaid services provided tonon-free territory. 5
  6. 6. For the first four services mentioned (international call centers, electronic mailboxes, distancetraining, issuance of electronic signature certificates), the tax treatment will be the same as ifthe services where rendered from abroad.Moreover, if the free trade zone user renders any other service listed above (services forproduction of logical supports, IT advice and IT training, management, administration, accountingand similar services provided to related entities devoted to provisioning and port logistics services,provided they do not exceed 20% of total income for the year) free trade zone tax exceptionswill not apply to those specific services and the tax user must pay taxes under the general taxsystem in relation to those services.20 6
  7. 7. 3. TAX ADVANTAGESThe Free Trade Zone Law (No. 15,921) establishes that free trade zone users are exempt fromall current and future national taxes.21This exemption includes, among others, Income Tax on earnings obtained by users, Net WorthTax on the assets and credits held by users, and Value-Added Tax. It also covers distributions ofdividends by users to their local or foreign, individual or legal entity shareholders.The circulation of goods and services within the free trade zone is also covered by the Value-Added Tax exemption.22 If services are provided within the free trade zone by a non-user, theywill be exempt from VAT only if because of their nature they cannot be provided from outside thefree trade zone.23The broad exemption mentioned in the first paragraph does not cover taxes on the income ofemployees working for free trade zone users or special social security contributions.24For Uruguayan employees remuneration is subject to payment of Individual Income Tax (IRPF)at progressive rates of from 0 to 25%. For social security contributions the same regimenapplicable in the rest of national territory applies to free trade zones. In the case of Uruguayanemployees the company must withhold approximately from 19.625% to 21.125% of their nominalremuneration as employee contribution, save exceptional situations where the percentage is less.In turn, the company must pay approximately 12.625% of the employees’ nominal remunerationas employer contribution.Foreign employees, instead, may opt out of the Uruguayan social security system.25 If theytake this option, neither the company nor the foreign employee have to make the aforesaidcontributions. Additionally, the decision to opt out of the Uruguayan social security system allowsthe foreign employee to choose between paying the Personal Income Tax (IRPF) or the NonresidentIncome Tax (IRNR) at a fixed rate of 12% on nominal remuneration.26 The tax must be paid in bythe company, which must withhold the tax amount upon paying remuneration to its employees.It is important to note that users cannot have over 25% foreign personnel. Except uponauthorization by the Ministry of Economy and Finance, 75% of personnel working at the companymust be Uruguayan, otherwise the company may forfeit its tax benefits.27 7
  8. 8. 4. OTHER BENEFITSIn addition to tax benefits, other benefits are available to users:// Government monopolies on utility services are not applicable in free trade zones.28Consequently, for example, a company established in a free trade zone would be authorized tohire telephone service from a company other than the State-owned telecom.// Foreign exchange, securities and precious metals may enter and leave free trade zones freelyand circulate freely within them.29// Goods and raw materials introduced from non-free territory to the free trade zone areconsidered exports. Similarly, provision of services to the free trade zone is governed by therules on exports of services.30 Industrial services provided on goods sent from the free tradezone to non-free national territory under temporary admission are considered exports of servicesand hence are not subject to VAT.31 8
  9. 9. 5. STEPS TO START OPERATINGTo be entitled to the tax benefits mentioned in the foregoing chapter the company must obtainUser status. In the case of a legal entity, the first step for obtaining User status is to choose thecorporate vehicle that is going to be used.a. Organization of a companyThe investor can choose the corporate vehicle most in line with its needs (corporation, branch,limited liability company, or others).Company shareholders may be local or foreign individuals or legal entities, and shares may beregistered or bearer.The sole restriction is that the purpose of the company or branch must be strictly limited to theprovision of services within the free trade zone and/or abroad.If the investor decides to organize a company, it may opt between a tailor-made or an off-the-shelf company. Organization of a tailor-made company takes approximately four months as ofsignature of the organization papers. The timeframe for organizing an off-the-shelf company isapproximately 72 hours as of remittance of the pertinent documentation to the organizer.If the decision involves organizing a branch of a foreign parent it is not necessary to amend theparent’s bylaws, provided the bylaws allow it to act outside the country of its incorporation.To accredit the above it will be necessary to produce the following documentation:// Notarized copy of parent company’s bylaws and any amendments.// Certificate of existence and representation of parent.// Minutes of meeting of parent’s shareholders or board of directors (as applicable) resolvingto set up a branch in Uruguay, allocating capital and appointing representative/s of the branch.We note that while there are no residence or nationality requirements for the branch’s legalrepresentative, as of the tax reform that took effect on July 1, 2007, the branch must have atax representative residing in Uruguay.// Granting of powers of attorney to represent the company and perform procedures for registration. 9
  10. 10. Once such documentation has been legalized, the process under Uruguayan law for recognition ofthe parent takes from 30 to 45 days. The process involves:// Filing with the National Registry of Commerce of the incorporation papers, the companyresolution to establish a branch in Uruguay, appointment of the person/s who shall administer orrepresent same, and indication of the capital allocated.// Making the publications required by law for companies organized in Uruguay, according to type.// Registering the branch with Uruguayan tax and social security authorities.We note that the accounting books of such companies must necessarily be filed with authoritiesin Uruguayan pesos.b. Execution of a (direct or indirect) user agreementOnce the company is established, the user must sign an agreement with the free trade zoneoperator. This would be the case of a direct user.The other possibility is to become an indirect user, by executing an agreement with a direct userto sublease use of its facilities.c. Business Plan preparationTogether with the direct or indirect user agreement, the company must file a detailed descriptionof the activities to be performed, a business plan and the investment to be made for the firstthree years, and indication of the number of persons to be employed.Similarly, if the company has registered shares it must file a list of its shareholders and theirdomiciles. If the company has bearer shares it must report the names and domiciles of itsdirectors.32 If the company is the affiliate of a foreign company without establishing a branch, itshould indicate the parent company abroad and where it is located.d. Authorization of Free Trade Zone AreaOnce the documentation has been prepared, it is to be filed with the Free Trade Zones Area forconsideration. Normally that authority takes two months to analyze the documents and to grantthe applicant User status. Upon approval, the company may begin operating and enjoying all thebenefits mentioned in chapter three. 10
  11. 11. 6. LEGAL SECURITYThe Free Trade Zones Law (No. 15,921) declares the promotion and development of free tradezones to be in the national interest.33In the same Law the Uruguayan Government guarantees free trade zone users the tax exemptionsand benefits for the full term of their user agreements, under liability for damages. The samecommitment was included in the decree authorizing creation of Aguada Park.34By virtue of the above, any change detracting from the user’s situation during the term of theagreement must be indemnified by the Uruguayan Government.The rules also establish that if the Executive Branch were to revoke the free trade zone operator’sauthorization, the Executive must adopt the measures necessary to maintain infrastructure andother essential services for the free trade zone to continue operating normally.35From a political standpoint, we note that the free trade zone system has been in place for over30 years in Uruguay and over that time the different administrations have tended to step up thesystem. Evidence of this is that there are currently 12 free trade zones that were authorizedunder administrations headed up by different political parties.Additional proof of the political commitment assumed by the Uruguayan Government in connectionwith free trade zones is the fact that the tax advantages afforded to free trade zone usershave remained unaffected despite the changes introduced in the tax reform law implemented in2007. 11
  12. 12. 7. GOVERNMENT OVERSIGHTFree trade zones are subject to oversight by the Free Trade Zones Area (an agency of theMinistry of Economy and Finance) which –among other powers- has the authority to approveuser establishment.36Additionally, given that free trade zones are part of Uruguayan territory, companies establishedthere are subject to control by the different government authorities on all companies withinnational territory. For example, free trade zone users must file their financial statements withthe General Revenue Service per applicable requirements. Similarly, they must comply with alllabor and social security rules applicable in Uruguay and may be inspected by the respectiveauthorities. 12
  13. 13. Regulatory References1. Resolution 486/007, art. 1: “ITSEN S.A is hereby authorized to operate a private free tradezones for services under the regimen of Law 15,921 of December 17, 1987, its RegulatoryDecree No. 454/988 of July 8, 1988, and other applicable rules (…).”2. Law 15,921, art. 2 (as drafted in art. 65 of Law 17,292): “Free trade zones are publicly orprivately owned areas of national territory, fenced in and efficiently isolated, as determined bythe Executive Branch upon the advice of the Honorary Free Trade Zones Advisory Commission,for development therein, with the tax exemptions and other benefits set forth in this law, of alltypes of industrial, commercial or service activities, including (…) C) Provision of all types ofservices not restricted under national law, both within the free trade zone and from same tothird countries (…).”3. Law 18,083, art. 102: “The companies indicated in article 17 of Law No. 15,921 of Dec-ember 17, 1987 may engage in all types of activities outside national territory or within a freetrade zone to the benefit of direct or indirect users of any free trade zone.”4. Law 15,921, art. 14: “Free trade zone users are all individuals or legal entities who acquirethe right to engage therein in any of the activities referred to in article 2 (...).” In turn, art. 15establishes that: “Direct users are those who acquire the right to operate in a free trade zonevia an agreement with the free trade zone operator, be it the Government or a duly authorizedprivate party. In all circumstances, for these purposes, the Government may contract directlythrough the Free Trade Zones Office and the user is to provide a guarantee. Direct users arethose who acquire the right to operate in a free trade zone by means of an agreement executedwith a direct user to use or enjoy its facilities.”5. Law 15,921, art. 16: “Agreements executed by free trade zone operators with direct users,or executed by direct users with indirect user, and which regulate rights of free trade zoneuse shall be deemed nonexistent if they have not first been approved by the Free Trade ZonesOffice.”6. Law 15,921, art. 19: “Free trade zone users are exempt from all existing or future nationaltaxes, including those which by law require specific exemption, with respect to the activitiesthey perform therein.”7. Law 15,921, art. 20: “The aforesaid tax exemptions do not include special social securitycontributions and the legal benefits of a pecuniary nature established for nongovernmentalsocial security persons under public law. When the foreign personnel working in a free trade 13
  14. 14. zone opts out (in writing) of the Uruguayan social security system there shall be no obligationto make the pertinent contributions.”8. Resolution 486/007, art. 1: “ITSEN S.A. is hereby authorized to operate a private freetrade zone for services (…).”9. An example of such exceptions is set forth in the Decree of March 20, 2006, which esta-blishes that free trade zone users may engage in services of software production, IT advice,and IT training, from a free trade zone to non-free territory, which until then was not permittedfor them. The decree indicates that when this is the case, companies must pay taxes per thegeneral tax regimen, i.e., they are not entitled to the tax benefits available to free trade zoneusers.10. Law 15,921, art. 14: “(...) Companies established in free trade zones cannot engage inindustrial, commercial and service activities outside of same.”11. Law 15,921, art. 18: “Free trade zone users must employ in the activities they performtherein at least 75% (seventy-five percent) of natural or legal Uruguayan citizens, in order tomaintain their status as users and the tax exonerations, exemptions, benefits and rights affor-ded them by this law. In exceptional cases this percentage may be reduced upon authorizationby the Executive Branch, in the light of special features of the activity to be performed andreasons of general interest.”12. Law 15,921, art. 42: “Violations and infractions of this Law, its regulations and contractstipulations shall be penalized by the Executive Branch: a) with a fine of up to N$ 50,000,000(fifty million new pesos) to be adjusted per the Consumer Price Index established by the GeneralOffice of Statistics and Census; (b) with a prohibition from (…) performing any operation asuser for a specific period; and (c) with forfeiture of the exemptions and other benefits affordedby this law.”13. Law 15,921, art. 1: “The promotion and development of free trade zones, for the purposeof promoting investment, expanding exports, increasing use of national labor, and fosteringinternational economic integration, are declared to be in the national interest.”14. Law 15,921, art. 25: “The Government, under liability for damages, guarantees the userduring effectiveness of its agreement the tax exemptions, benefits and rights that this lawaffords the user.”15. Decree 71/001, art. 3: ”The number of incoming and outgoing calls, of telephone servicesprovided by international call centers to national territory must be less than 50% of the totalcalls of the telephone services provided by such international call centers.” 14
  15. 15. 16. Law 15,921, art. 2 (as drafted in art. 65 of Law 17,292): “(...) Free trade zone usersmay also provide the following telephone or IT services from free trade zones to non-free na-tional territory, respecting government exclusivities, monopolies and/or public concessions: 1)international call centers, excluding those solely or primarily for national territory; 2) electronicmailboxes; 3) distance training; 4) issuance of electronic signature certificates.The above services shall receive the same tax treatment as services provided from abroad asregards the provider, as well as regards the deductibility thereof by the receiver.”17. Decree 496/007. art.1: “Free trade zone users may engage in the following services fromfree trade zones to non-free national territory: a) logical support production services, IT advice,and IT training.”18. Decree 496/007, art. 1: “ (…) b) management, administration, accounting and similarservices provided to related entities devoted to provisioning and port logistics services, provi-ded rendering of such services does not exceed 20% (twenty percent) of total income for theyear.”19. Law 15,921, art. 2: “Free trade zones are publicly or privately owned areas of nationalterritory, fenced in and efficiently isolated, as determined by the Executive Branch upon theadvice of the Honorary Free Trade Zones Advisory Commission, for development therein, withthe tax exemptions and other benefits set forth in this law, of all types of industrial, commercialor service activities, including (…) D) others that, at the discretion of the Executive Branch,are beneficial for the national economy or for the economic and social integration of States.”20. Law 15,921, art. 2: “(…) In the event that by regulation the provision of additional servi-ces from the free trade zone to non-free territory is authorized, such services shall be coveredby the tax regimen in effect at the time of the authorization, which may be established based onpermanent tax withholding regimens, as established by the Executive Branch. ”21. Law 15,921, art. 19: “Free trade zone users are exempt from all existing or future nationaltaxes, including those which by law require specific exemption, with respect to the activitiesthey perform therein.”22. Decree 454/988, art. 43: “Exemption from Value-Added Tax shall apply to: a) the circu-lation of goods and the provision of services in free trade zones, (b) the introduction of goodsfrom abroad to free trade zones.”23. Decree 220/998, art. 1: “The operations included in the concept of exports of servicesare: (…) 7) Services rendered exclusively in (…) free trade zones defined per Article 1 of LawNo, 15,921 of December 17, 1987. For such services to be considered exports they must 15
  16. 16. necessarily be provided in the said areas (…).” This criterion was confirmed by the GeneralRevenue Service in various revenue rulings (for example: Rulings Nos. 4734, 4865 and 4935).24. Law 15,921, art. 20: “The aforesaid tax exemptions do not include special social securitycontributions and the legal benefits of a pecuniary nature established for nongovernmentalsocial security persons under public law. When the foreign personnel working in a free tradezone opts out (in writing) of the Uruguayan social security system there shall be no obligationto make the pertinent contributions.”25. Law 15,921, art. 20: “(...)When the foreign personnel working in a free trade zone optsout (in writing) of the Uruguayan social security system there shall be no obligation to make thepertinent contributions.”26. Law 18,083, Title 7, art. 7: ” (...) Non-Uruguayan nationals rendering personal services infree trade zones and excluded from the general Social Security Administration contribution re-gimen, pursuant to article 20 of Law No. 15,921 of December 17, 1987, may opt to pay taxeson their employment income via the Nonresident Income Tax. The aforesaid option may only beexercised with respect to those services rendered exclusively in the free trade zone, and suchservices may not directly or indirectly form part of other services provisions to residents innon-free national territory.”27. Decree 454/988, art. 33: “In cases where a user wishes to employ more than twenty-five percent foreign personnel it must file such a request in writing with the Free Trade ZonesOffice, indicating the grounds for same. The said Office shall submit a report to the Ministry ofEconomy and Finance for its decision.”28. Law 15,921, art. 24: “Government agencies that supply inputs or services to free tradezone users may establish special promotional rates for same. Government industrial and com-mercial services monopolies shall not apply in free trade zones.”29. Law 15,921, art 38: “Securities, foreign and national currency, and precious metals mayenter and leave free trade zones freely and be held, circulated or transferred freely therein.30. Law 15,921, art. 21: “(…) Goods, services, merchandise and raw materials coming fromnon-free national territory and brought into free trade zones shall be governed by the samerules in effect for exports at that time.”31. Decree 220/998, art. 34: “Operations included in the concept of services exports are:(…) 4) industrial services rendered in national customs territory, provided they comply withthe following conditions: a) that such services are performed on goods consigned from outsidenational customs territory, under a temporary admission regimen, without exchange operationsand with the consignor maintaining ownership thereof during their stay in national customs 16
  17. 17. territory; and (b) that the said goods are brought in under the framework of the said regimendirectly by the manufacturer providing toll manufacturing services, who must reexport sameoutside national customs territory and shall be the only one recognized as exporter of services.Reexported merchandise may in no case be brought into national customs territory in thesame state, or transformed, or as part of other goods. The General Revenue Service and theNational Customs Service shall establish the pertinent controls to ensure compliance with theconditions set forth in this section.”32. Resolution by Ministry of Economy and Finance, General Office of Trade, Free Trade ZonesOffice (May 9, 2006), art. 1: “As of June 1, 2006, the following documentation is to be filedtogether with direct and indirect user agreements submitted for approval of the Free TradeZones Office of the General Office of Trade: (a) if the user is a registered share corporation, itmust include a list of shareholders, including domiciles of same at the date of filing of the agre-ement; if it is a bearer share corporation, it must include the name and domicile in Uruguay ofthe members of the Board of Directors in office at that date. Notwithstanding compliance withthe above, when the user is the affiliate of a foreign company without establishing a branch orpermanent representation, the foreign parent and the location of its offices must be identified;(b) brief presentation of the business plan to be implemented over the first three years; (c)detailed indication of number of persons to be employed.”.33. Law 15,921, art. 1: “The promotion and development of free trade zones, for the purposeof promoting investment, expanding exports, increasing use of national labor, and fosteringinternational economic integration, are declared to be in the national interest.”34. Resolution 486/007, art. 3: ”The Government, under liability for damages, assures the freetrade zone users that it authorizes, during the effectiveness of their respective agreements,the tax exemptions, benefits and rights afforded by Law No. 15,921 of December 17, 1987.”35. Decree 454/988, art. 22: “In the event that authorization to operate is revoked, theExecutive may order adoption through the Free Trade Zones Office of the necessary transitorymeasures for maintenance of the infrastructure and supply of essential services for proper andnormal functioning of the free trade zone (…). The measures ordered as indicated above shallnot imply substitution or assignment to the Free Trade Zones Office of the agreements executedbetween the users and the operator.”36. Law 15,921, art. 5: “Administration, supervision and control of free trade zones shall restwith the Ministry of Economy and Finance through the Free Trade Zones Office, which may begranted appropriate authority for proper fulfillment of its functions.” 17

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