Double Taxation Treaty between Argentina And Luxembourg

Author:Canosa Abogados
Profession:Canosa Abogados
 
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On April 13, 2019, Argentina and Luxembourg executed a Treaty to prevent double taxation ("DTT"). This DTT is not yet in force because that legislative ratification of both countries has not been approved. It was written according to the OECD Model Convention, with update clauses based on the latest international recommendations.

In this sense, it contemplates the following imposition ceilings:

Permanent Establishment: The traditional definition of Permanent Establishment is followed, and no reference has been incorporated into the concept of "significant digital presence" promoted by the OECD within the framework of the BEPS rules. Dividends: Limits 10% of the gross amount of the dividends if the effective beneficiary is a company that directly owns at least 25 percent of the capital of the company that pays the dividends, this percentage should have been held by the beneficiary for a period not less to 364 days before payment. 15% in all other cases. Interest: A maximum of 12% is established over the gross amount of interests for the...

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