Argentina–MNE Tax

Americas

OECD and Ireland strike tax deal as others in EU line up, developing countries shrug

October 7, 2021

Ireland announced October 7 that it is joining the OECD tax deal, cutting the holdouts down to just five nations out of the 140 in the Inclusive Framework that are scheduled to meet Friday, October 8, to . . .

Americas

Argentina to end tax on exported services

October 1, 2021

The Argentine government announced on September 24 that it will eliminate the tax on exported services beginning in . . .

Africa

G-24 warns that global tax deal will fail without better terms for developing countries

September 21, 2021

An international tax agreement on new profit allocation rules and a minimum tax will “not be sustainable even in the medium run” unless the terms allow developing countries to see fair shares under both pillars of the deal, the G-24 contended in September 19 comments submitted . . .

Americas

Argentine Supreme Court rules against Molinos in tax treaty abuse case

September 20, 2021

Hernán Ubertazzi, 3D Asesores, discusses Argentina’s Supreme Court’s September 2 endorsement of the Argentine Tax Authority’s position regarding the abuse by Molinos Río de La Plata of the Argentina-Chile double taxation agreement, in a case involving . . .

Americas

ICAP multilateral tax risk assurance program applications due September 30

September 2, 2021

Multinational entities interested in participating in the first full round of the OECD Forum on Tax Administration (FTA) International Compliance Assurance Programme (ICAP) have until September 30 to submit the . . .

Accounting

Dozen countries deemed ‘highly inflationary’ for accounting standard purposes

August 23, 2021

The Center for Audit Quality, in a report published August 20, flagged 12 economies as potentially highly inflationary for purposes of US GAAP Accounting Standards Codification (ASC) 830, Foreign currency matters.

Africa

Countries take diverse transfer pricing approaches to financial transactions, profit attributions

August 4, 2021

Updated transfer pricing country profiles released by the OECD on August 3 include for the first time information on 20 reviewed countries’ transfer pricing rules applicable to . . .

Africa

Ireland, Lithuania, Hungary offer lowest tax rates for R&D, OECD study finds

August 2, 2021

An OECD taxation working paper on corporate effective tax rates for research and development (R&D) released on July 29 reports that the effective average tax rate on R&D investments in Ireland, Lithuania, and Hungary range from -2% to -4% – suggesting . . .

Africa

Tax dispute peer reviews find Argentine, South African APA programs wanting, Indian MAP issues

July 27, 2021

The latest peer review assessments of countries’ efforts to meet the minimum standard for tax dispute resolution, released by the OECD on July 26, report that both Argentina and South Africa fail the first prong regarding preventing . . .

Americas

Argentina’s Economy Minister says 15% rate for global minimum corporate tax is too low, seeks rate of 21%–25%: Buenos Aires Times→

June 29, 2021

Antigua and Barbuda

Antigua and Barbuda, Argentina, Russia, South Africa, and Ukraine make progress on meeting international standard on tax transparency and exchange of information in latest peer reviews: OECD→

June 24, 2021

Africa

Irish tax treaty commentators disagree on approach to new negotiations

June 23, 2021

Comments from business groups and non-governmental organizations, published June 21, in response to Ireland’s public consultation on its tax treaty policy identified several jurisdictions where . . .

Africa

G20 draft communique reportedly endorses global minimum tax

June 22, 2021

A draft communique for the upcoming G20 finance ministers meeting on July 9–10 includes language expressing the countries’ support for a global minimum tax and new rules . . .

Americas

Argentina establishes simplified transfer pricing reporting regime

June 22, 2021

Hernán Ubertazzi, 3D Asesores, discusses the Argentine tax agency’s June 18 guidance simplifying the transfer pricing reporting regime to alleviate burdens on taxpayers that are considered . . .

Americas

Argentina introduces progressive corporate income tax

June 14, 2021

Rodrigo Marabi, LM Abogados, discusses the Argentine Congress’ approval on June 2 of a corporate income tax reform replacing the 30% fixed rate with a progressive tax rate . . .

Americas

Argentina issues pandemic-related transfer pricing relief, guidance

May 27, 2021

Hernán Ubertazzi, 3D Asesores, discusses the Argentina tax agency’s announcement on April 30 on transfer pricing documentation deadlines and recommendations regarding the treatment of controlled transactions that took place during the pandemic . . .

Americas

Argentina extends transfer pricing deadlines due to COVID-19: AFIP (in Spanish)→

May 11, 2021

Americas

US, Argentina agree to exchange country-by-country reports on large multinationals

January 28, 2021

The US and Argentina have signed a competent authority agreement to exchange . . .

Americas

OECD adds transfer pricing country profiles for Argentina, Dominican Republic: OECD→

January 15, 2021

Africa

OECD publishes details on 40 countries’ uptake of transfer pricing rules for hard-to-value intangibles

December 16, 2020

The OECD today published 40 responses to a questionnaire that asked officials whether their country has adopted transfer pricing rules for . . .

Americas

OECD publishes report on tax policy reforms enacted both before and after COVID-19 in 37 OECD member countries plus Argentina, China, Indonesia, South Africa: OECD→

September 4, 2020

Americas

Argentina issues burdensome draft transfer pricing guidance for public comment

October 7, 2019

Elisa Kaminsky, a senior associate at BaseFirma, Miami, discusses an October 2 public consultation on new Argentina transfer pricing guidance which includes significant and burdensome new requirements . . .

Africa

OECD report discusses tax reform, trends in OECD countries and Argentina, Indonesia, South Africa: OECD→

September 7, 2019

Africa

CIAT database reflects progress made by 15 countries implementing BEPS recommendations

August 9, 2019

In an August 8 update, the Inter-American Center of Tax Administrations (CIAT) has reported on 15 member countries’ progress adopting . . .

Americas

Japan, Argentina sign tax treaty

June 30, 2019

Japan’s Ministry of Finance on June 27 announced . . .

Americas

Argentina offers new tax incentives for high tech businesses

June 17, 2019

Sandra Diaz a partner at Basa Firma, writes about Argentina tax incentives, enacted June 6, designed to encourage high technology businesses to locate there . . .

Americas

Argentina modifies transfer pricing regime

May 29, 2019

Sandra Diaz, a partner with Basa Firma, discusses changes to Argentina’s transfer pricing requirements published on May 27 . . .

Americas

Argentina suspends new rules for taxing nonresident capital gains: KPMG→

August 3, 2017

Africa

New CIAT database tracks BEPS implementation in 36 countries

February 22, 2019

The Inter-American Center of Tax Administrations (CIAT) on February 21 released . . .

Swiss Federal Council adopts MLI

August 22, 2018

The Swiss Federal Council on August 22 adopted a dispatch on the Multilateral Convention to Implement Tax Treaty . . .

Americas

Argentina tax reform adds sixth method, other transfer pricing revisions: KPMG→

January 8, 2018

Americas

US tax officials discuss coming country-by-country reporting guidance, treaties, other initiatives

December 19, 2016

The US intends to release tax guidance on country-by-country reporting for MNEs that addresses reporting for LLCs in US groups and for tiered partnerships, officials said at a December 15-16 tax conference. Officials also discussed just-released final regs on outbound transfers of goodwill, US tax treaty negotiations, and the pending EU State aid. . .

Americas

OECD asks MNEs for feedback on cross-border tax dispute resolution in Argentina, Chile, Colombia, Croatia, India, Latvia, Lithuania, South Africa

July 26, 2018

The OECD is seeking feedback on multinationals’ experience with cross-border tax dispute resolution procedures in . . .

Switzerland consults on introducing automatic exchange of tax information with 22 countries

December 1, 2016

The Swiss government has today announced a consultation on commencing automatic exchange of information in tax matters with 22 countries, writes Davide Anghileri, a lecturer at the University of Lausanne . . .

Americas

CIAT preparing “sixth method” transfer pricing database

April 9, 2019

Robert Feinschreiber of Charles River Associates and Margaret Kent of Transfer Pricing Consortium discuss CIAT’s new transfer pricing database for use in applying the sixth method . . .

Americas

Japan, Argentina agree to terms of tax treaty

December 3, 2018

The governments of Japan and Argentina have agreed in principle to the terms of a tax treaty between . . .

Americas

Argentina tax reform bill includes corporate rate reduction: EY→

November 3, 2017

Americas

Japan, Argentina negotiating tax treaty

January 9, 2018

Japan’s Ministry of Finance today announced that the governments of Japan and Argentina will commence negotiations . . .

Africa

Australia releases draft law adopting BEPS MLI, seeks to amend 30 bilateral tax treaties

February 8, 2018

The Australian government on February 8 released for public comment a draft law that would give the force of law to a multilateral tax treaty designed to amend about 30 of Australia’s tax treaties with other . . .

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin