Articles

 

Argetina's Tax Amnesty Program and Tax Reform

by Cristian E. Rosso Alba; The Federal Executive Branch has sent to the Congress a tax amnesty package and a tax reform. The article delves into these news, while the Congressional debate takes place..
Read Article

Managing Corporate Taxation in Latin American Countries

by Cristian E. Rosso Alba; Juan Manuel Soria; LATAXNET The document attached includes a summary of the Corporate Tax framework applicable in eighteen selected countries in Latin America.
Read Article

What to Learn From Transfer Pricing Controversies in Argentina

by Cristian E. Rosso Alba; The document attached includes a summary of the lessons learned from more than ten years of experience in transfer-pricing tax controversy, a core practice of the firm.
Read Article

Revenue Service Reinforces Tax Rules on Outbound Payments

by Cristian E. Rosso Alba; Daniel Dominguez; Jean Anton Under a new resolution introduced by the Argentine Revenue Service (ARS), taxpayers will be required, as of February 1, to file with the ARS an anticipated declaration of cross-border payments (Resolution 3417/ 2012). Another resolution introducing a new tax information regime for financial instruments will enter into force this month (Resolution 3421/2012). The resolutions are part of a continuing ARS initiative to use tax regulations to control cross-border foreign exchange transactions. In 2012 two other regulations were implemented in connection with the initiative: • As of February 1, 2012, importers of goods were required to file an anticipated sworn statement (the DJAI) identifying the goods they planned to import. Although the statement was intended merely to inform the tax authorities of the importers’ intentions, the ARS reserved the rights to reject the DJAI, in which case the goods would not receive customs clearance. • As of April 1, 2012, another reporting requirement was introduced in the form of a sworn statement for cross-border payments for services (the DJAS). In this case, the ARS reserved the right to make observations about purchases of foreign currency to honor the cross-border payments. The new regulations broaden the scope of these information regimes by expanding them to include crossborder payments of dividends, interest, and so on.
Read Article

Argentina to Terminate Income Tax Teatries with Chile, Spain

by Cristian E. Rosso Alba; Argentina has made initial moves to terminate two more income tax treaties. The government on June 30 announced that it will terminate its tax treaty with Chile,1 and on July 16 it published in the official gazette the denouncement of its tax treaty with Spain.
Read Article

Tax Authority Extends Reporting Obligations to Foreign Trusts

by Cristian E. Rosso Alba; The Argentine Revenue Service (ARS) on April 19 published General Resolution 3312, which broadens the scope of the registration and reporting obligations (previously limited to domestic trusts) to target foreign trusts and other equivalent foreign structures that have a substantial nexus with an Argentine party (that is, when the settlor, trustee, or any beneficiary is located in Argentina).
Read Article

Doing Business in Argentina: Tax Overview

by Cristian E. Rosso Alba; Doing Business in Argentina: Tax Overview.
Read Article

Argentina Terminates Provisional Application of Tax Treaty With Switzerland

by Cristian E. Rosso Alba; Lucía Ibarreche On January 31 the Argentine official gazette published the Argentine government's decision to terminate unilaterally the provisional application of the tax treaty with Switzerland, a treaty that has generated controversy since its inception.
Read Article

Tax Penalty Amendments Move Through Congress

by Cristian E. Rosso Alba; Daniel Dominguez Argentine President Cristina Fernandez de Kirchner in December issued Decree 2120/2011,1 calling special sessions of the National Congress to discuss a series of unexpected tax proposals that were deemed of special importance for the recently reelected government's economic program.
Read Article

 

MORE