South American Real Estate News

Argentine Taxes: Individual – Foreign tax relief and tax treaties

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Foreign tax relief

Argentina has double tax treaties (DTTs) with a number of foreign countries for the purpose of eliminating double taxation. Where, according to the national laws of Argentina and another country, an individual would be subject to PIT on the same income in both countries, it must be ascertained whether relief or exemption from Argentine tax is available under a DTT. Most current treaties specify various tests to determine in which of the two countries an individual is a resident for treaty purposes.

Most treaties also contain clauses that exempt a resident of one country from tax on employment income outside the other country and on employment income in the other country if an individual is present in the other country for less than 183 days in a year, provided that certain conditions are met regarding the terms of employment.

Tax credits are available for income taxes paid abroad on foreign source income. The foreign tax credit should not exceed the portion of Argentine tax attributable to the foreign source income.

Tax treaties

Double taxation treaties

Argentina currently has DTTs with the countries below:

AustraliaFranceRussia
BelgiumGermanySpain
BoliviaItalySweden
BrazilJapan *Switzerland
CanadaLuxembourg *Turkey *
ChileMexicoUnited Arab Emirates
China *NetherlandsUnited Kingdom
DenmarkNorway
FinlandQatar *

* Treaties pending ratification.

Totalisation agreements

Argentina has currently entered into totalisation agreements with the following countries:

Belgium ***Italy
ChileLuxembourg ***
Colombia ***Mercosur **
Ecuador ***Peru ***
FrancePortugal
GreeceSlovenia ***
Ibero-American ****Spain

** Mercosur treaty includes Argentina, Brazil, Paraguay, and Uruguay.

*** Not currently operative.

**** Includes several Central and South American countries. Not currently operative.

Source: PWC Argentina

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