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Argentina

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Tax authorities

Administración Federal de Ingresos Publicos (AFIP)
Hipólito Yrigoyen 370, C1086ADD, Buenos Aires
Tel: +54 11 4347 2000
Website: www.afip.gov.ar

Tax rates at a glance

(As of September 2012)

Corporate income tax rate 35% (a)
Capital gains tax 35%
Branch tax 35% (b)
Withholding tax
  Dividends 0% 35% (c)
  Interest 15.05% (d)
  Royalties 12.25% 21% 28% 31.5% (e)
  Branch remittance tax 0%
Net operating losses (years)
  Carryback 0
  Carryforward 5

  1. A 1% asset tax, which operates as a minimum income tax, is imposed on corporate assets, including shareholdings in foreign companies (but not holdings in resident companies). Asset tax paid may be credited against the company's income tax liability for up to 10 fiscal years.
  2. Branches are taxed at the same rate as domestic companies. There is no branch remittance tax.
  3. Dividends paid to non-resident shareholders generally are exempt from withholding tax. However, a 35% rate is imposed (via withholding) on profit distributions, including dividends, that exceed taxable accumulated profits.
  4. The general 35% withholding tax is reduced to 15.05% if the borrower is a financial institution; the lender is a bank or financial institution located in a non-tax haven jurisdiction; the interest relates to certain bonds registered in countries that have concluded an investment protection agreement with Argentina; or the transaction involves the financing by a seller of depreciable movable property.
  5. Royalty payments made to non-residents for the exploitation of copyrights in Argentina are subject to a final withholding tax of 35% on 28% of the gross payment effective rate of 12.25%, provided the works are registered with the National Copyright Bureau and other conditions are satisfied. Patent royalties and fees for technical assistance, engineering or consulting services paid to non-residents are subject to a final withholding tax of 35% on a prescribed percentage of the gross payment, which varies according to the type of payment. The effective withholding tax rates are 28% (35% x 80%) on patent royalties and 21% (35% x 60%) on fees for technical assistance, engineering or consulting services if the agreement under which the royalties or fees are paid is registered by the National Institute of Industrial Technology (INTI) and, in the case of fees, the services cannot be obtained in Argentina. If these conditions are not satisfied, the effective rate on the royalties or fees is 31.5% (35% x 90%).

Argentina

Andres Edelstein and Ignacio Rodriguez
PwC
Buenos Aires

The termination of three tax treaties by Argentina could have serious repercussions for taxpayers, as could the tax reform that is likely to be introduced there soon, say Andres Edelstein and Ignacio Rodriguez of PwC

[Show full article]

Tax

"This government has ideas that date back to the '70s when the government owned a lot of properties," was one comment about the mood prevailing in Argentina after an eventful last 12 months. Decisions made by Cristina Fernandez de Kirchner's government ... [more]

Marval, O'Farrell & Mairal, one of Argentina's largest law firms, also has one of the largest tax practices, employing three full-time partners – Gabriel Gotlib, Horacio García Prieto and Walter Keiniger, one part-time partner and 34 associates.As one ... [more]

PwC

PwC in Argentina is a multidisciplinary practice comprising a tax group and a legal group that offer services in transfer pricing, international tax, tax litigation, labour and social security, customs and indirect tax and corporate legal. The tax practice ... [more]

Rosso Alba, Francia & Asociados, headed by Cristian Rosso Alba, remains a full tax practice group after parting ways with Mitrani, Caballero & Ojam in April 2012. Earlier this year, the firm hired Martin Graña, a senior transfer pricing director from ... [more]

With a dedicated tax and customs practice of four partners and 15 fee earners, Bruchou, Fernandez Madero & Lombardi -Taxand is one of the country's largest law firms with a tax practice. Matías Olivero Vila, who has been the vice president of the Argentine ... [more]

Pistrelli, Henry Martin y Asociados, an Ernst & Young member firm, boasts strength in all areas of international tax services. The team is known for cross-border integration and a strong market presence, winning work from the country's major companies. ... [more]

Pérez Alati, Grondona, Benites, Arntsen & Martínez de Hoz Jr (PAGBAM) is a full-service law firm, with, in the view of its peers, a strong tax practice and high-level clients. "We see them often, involved in the major tax matters and tax controversies ... [more]

Teijeiro & Ballone Abogados began operating on August 1 2012 under the leadership of Guillermo Teijeiro and Mariano Ballone who were the senior partners in the tax practice of Negri & Teijeiro. The firm's other two partners are Ana Lucía Ferreyra and ... [more]

Asorey & Navarrine is a boutique tax firm active in the areas of income tax, indirect tax and tax controversy. They choose not to practise transfer pricing, leaving that area to the accounting firms. Led by founding partner, Rubén Asorey, the firm's ... [more]

Baker & McKenzie has developed a strong tax practice in the financial services sector serving such clients as HSBC, UBS, Barclays and their local subsidiaries. Their tax practice group, led by Martin Barreiro and Joaquin Kersman, comprises three partners ... [more]

Led by Guillermo Perez, Grupo GNP's tax practice covers all main tax practice areas – indirect tax, transfer pricing, corporate tax and tax disputes. Most of the firm's employees have come from one of the larger accounting firms. Perez himself was formerly ... [more]

Established in 1991 by Cecilia Goldemberg, the tax practice of Goldemberg & Asociados has grown to include seven partners and 26 fee earners. The firm also employs accountants and economists, enabling them to provide consultancy, tax planning, transfer ... [more]

JP O'Farrell Abogados is a full-service law firm whose tax practice is headed by founding partner John O'Farrell and Gastón Vidal Quera, who was promoted to partner in May 2012. The firm's tax team serves clients such as Akzo Nobel, John Deere and Husqvarna, ... [more]

See also

Argentina
Latin America

Firm contact details