Switzerland – Argentina: Tax Treaty Enters into Force
The new Income and Capital Tax Treaty between Switzerland and Argentina entered into force on 27 November 2015.
The new treaty generally applies from 1 January 2015 for withholding taxes and from 1 January 2016 for other taxes and article 25 (Exchange of information).
The new agreement will replace the agreement of 1997, which was denounced by Argentina on 16 January 2012.
In accordance with the new treaty, the following withholding taxes will apply:
Dividends:
- 10% if the beneficial owner is a company (other than a partnership) which holds directly at least 25% of the capital of the company paying the dividends.
- 15% in all other cases.
Interest:
- 0% if the interest is paid with respect to indebtedness arising as a consequence of the sale on credit of any industrial machinery or equipment.
- 0% if the interest is paid with respect to any development loan granted by a bank to an unrelated party at a preferential rate provided the time period of such loan is no less than 3 years.
- 12% in all other cases.
Royalties:
- 3% of the gross amount paid for the use of, or the right to use, news.
- 5% of the gross amount paid for the use of, or the right to use, copyright of literary, dramatic, musical or other artistic work (but not including royalties in respect of motion picture films and works on film or videotape or other means of reproduction for use in connection with television).
- 10% of the gross amount paid for the use of, or the right to use, industrial, commercial or scientific equipment or any patent, trade mark, design or model, plan, secret formula or process, computer software or for information concerning industrial or scientific experience including payments for the rendering of technical assistance.
- 15% in all other cases.
