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10 July 2018

Argentina and Brazil Amendment Protocol to income tax treaty enters into force on 29 July 2018

The Amendment Protocol (the Amendment Protocol) to the Convention to Avoid Double Taxation and Prevent Fiscal Evasion (DTT) between Argentina and Brazil, signed on 21 July 2017, will enter into force on 29 July 2018. Argentina completed its internal procedures and notified Brazil on 24 May 2018. Brazil completed its internal procedures and notified Argentina on 29 June 2018. (For more information on the Amendment Protocol, see EY Global Tax Alert, Argentina and Brazil sign Amendment Protocol to income tax treaty, dated 1 August 2017.)

According to the Amendment Protocol, its provisions take effect:

  • For taxes withheld at source on income derived on or after 1 January 2019
  • For other taxes on income and taxes on capital chargeable for any tax year beginning on or after 1 January 2019

The Amendment Protocol contains important modifications to the current DTT, including reduced withholding tax rates for interest and royalties, a tax credit system for the avoidance of double taxation, a definition of "technical assistance" and "technical services," and several anti-abuse provisions that should be taken into account by both Argentine and Brazilian taxpayers.

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CONTACTS

For additional information with respect to this Alert, please contact the following:

Pistrelli, Henry Martin & Asociados S.R.L., Buenos Aires

  • Carlos Casanovas
    carlos.casanovas@ar.ey.com
  • Gustavo Scravaglieri
    gustavo.scravaglieri@ar.ey.com
  • Ariel Becher
    ariel.becher@ar.ey.com
  • Pablo Baroffio
    pablo.baroffio@ar.ey.com
  • Darío Corrente
    dario.corrente@ar.ey.com
  • Javier Herran
    javier.herran@ar.ey.com

Ernst & Young Serviços Tributários S.S., São Paulo

  • Orlando Veloci
    orlando.veloci@br.ey.com
  • Gustavo Carmona
    gustavo.carmona@br.ey.com
  • Rita A Martins
    rita.martins@br.ey.com
  • Ana Marra
    analucia.marra@br.ey.com
  • Audrei Okada
    audrei.okada@br.ey.com

Ernst & Young Serviços Tributários S.S., Rio de Janeiro

  • Mariano Manente
    mariano.manente@br.ey.com

Ernst & Young LLP (United Kingdom), Brazilian Tax Desk, London

  • Felipe Bastos Fortes
    ffortes@uk.ey.com

Ernst & Young LLP, Latin American Business Center, New York

  • Marcelo F. Lira
    marcelo.lira@ey.com
  • Pablo Wejcman
    pablo.wejcman@ey.com
  • Ana Mingramm
    ana.mingramm@ey.com
  • Enrique Perez Grovas
    enrique.perezgrovas@ey.com

Ernst & Young LLP (United Kingdom), Latin American Business Center, London

  • Jose Padilla
    jpadilla@uk.ey.com

Ernst & Young Tax Co., Latin America Tax Desk, Japan & Asia Pacific

  • Raul Moreno, Tokyo
    raul.moreno@jp.ey.com
  • Luis Coronado, Singapore
    luis.coronado@sg.ey.com

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ATTACHMENT

PDF version of this Tax Alert

Document ID: 2018-5845

 
 

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