International Tax 2026

Definitive global law guides offering comparative analysis from top-ranked lawyers

CHAMBERS GLOBAL PRACTICE GUIDES

International Tax 2026 Definitive global law guides offering comparative analysis from top-ranked lawyers

Contributing Editor Caroline Silberztein Baker McKenzie

Global Practice Guides

International Tax Contributing Editor Caroline Silberztein Baker McKenzie

2026

Chambers Global Practice Guides For more than 20 years, Chambers Global Guides have ranked lawyers and law firms across the world. Chambers now offer clients a new series of Global Practice Guides, which contain practical guidance on doing legal business in key jurisdictions. We use our knowledge of the world’s best lawyers to select leading law firms in each jurisdiction to write the ‘Law & Practice’ sections. In addition, the ‘Trends & Developments’ sections analyse trends and developments in local legal markets. Disclaimer: The information in this guide is provided for general reference only, not as specific legal advice. Views expressed by the authors are not necessarily the views of the law firms in which they practise. For specific legal advice, a lawyer should be consulted. Content Management Director Claire Oxborrow Content Manager Jonathan Mendelowitz Senior Content Reviewers Sally McGonigal, Ethne Withers, Deborah Sinclair, Stephen Dinkeldein, Vivienne Button and Sean Marshall Content Reviewers Lawrence Garrett, Marianne Page, Heather Palomino, Alison Moore, Adrian Ciechacki and Michael Irvine Content Coordination Manager Nancy Tsang Senior Content Coordinators Carla Cagnina and Delicia Tasinda Content Coordinator Joanna Chivers Head of Production Jasper John Production Coordinator Genevieve Sibayan

Published by Chambers and Partners 165 Fleet Street London EC4A 2AE Tel +44 20 7606 8844 Fax +44 20 7831 5662 Web www.chambers.com

Contents

INTRODUCTION Contributed by Caroline Silberztein, Baker McKenzie p.5

GREECE Law and Practice p.168 Contributed by Dryllerakis Law Firm IRELAND Law and Practice p.187 Contributed by A&L Goodbody Trends and Developments p.205 Contributed by A&L Goodbody

ARGENTINA Law and Practice p.8

Contributed by Rinci & Asociados Trends and Developments p.20 Contributed by Rinci & Asociados AUSTRIA Law and Practice p.28 Contributed by Schindler Attorneys

ITALY Law and Practice p.209

Contributed by Foglia & Partners Trends and Developments p.229 Contributed by Foglia & Partners

BELGIUM Law and Practice p.45 Contributed by Tiberghien

JAPAN Law and Practice p.236 Contributed by Anderson Mōri & Tomotsune Trends and Developments p.247 Contributed by Anderson Mōri & Tomotsune

BRAZIL Law and Practice p.57 Contributed by William Freire - Advogados Associados BULGARIA Law and Practice p.73 Contributed by Banchev and Grishina Law Firm Trends and Developments p.83 Contributed by Banchev and Grishina Law Firm

KAZAKHSTAN Law and Practice p.252 Contributed by GRATA International

LUXEMBOURG Law and Practice p.260 Contributed by Tiberghien Trends and Developments p.275 Contributed by Baker McKenzie Luxembourg MAURITIUS Law and Practice p.281 Contributed by CMS Prism in association with CMS

CHILE Law and Practice p.89 Contributed by Cortés Del Río Tax & Legal

CHINA Law and Practice p.105 Contributed by DaHui Lawyers Trends and Developments p.124 Contributed by Shihui Partners

MEXICO Law and Practice p.293

FINLAND Law and Practice p.130

Contributed by Escalante & Asociados Trends and Developments p.310 Contributed by Escalante & Asociados NORWAY Law and Practice p.316 Contributed by Aider Legal Trends and Developments p.327 Contributed by Aider Legal

Contributed by Svalner Atlas Finland Trends and Developments p.141 Contributed by Svalner Atlas Finland FRANCE Law and Practice p.146 Contributed by Bruzzo Dubucq GERMANY Law and Practice p.159 Contributed by MTR Legal Rechtsanwälte

3 CHAMBERS.COM

Contents

PANAMA Law and Practice p.333

SWEDEN Law and Practice p.443 Contributed by XR Legal Trends and Developments p.455 Contributed by XR Legal SWITZERLAND Law and Practice p.459 Contributed by Aegis Trends and Developments p.476 Contributed by Tax Partner AG

Contributed by Galindo, Arias & López Trends and Developments p.344 Contributed by Galindo, Arias & López PORTUGAL Law and Practice p.349 Contributed by CCA Law Firm Trends and Developments p.365 Contributed by CCA Law Firm PUERTO RICO Law and Practice p.371 Contributed by Maceira Zayas Trends and Developments p.379 Contributed by Maceira Zayas Contributed by DBS Private Bank Trends and Developments p.401 Contributed by DBS Private Bank SOUTH KOREA Law and Practice p.408 Contributed by Shin & Kim Trends and Developments p.422 Contributed by Yulchon LLC SINGAPORE Law and Practice p.385

UK Law and Practice p.483

Contributed by King & Spalding LLP Trends and Developments p.493 Contributed by King & Spalding LLP

USA Law and Practice p.499 Contributed by Weil, Gotshal & Manges LLP Trends and Developments p.512 Contributed by Weil, Gotshal & Manges LLP USA – NEW YORK Trends and Developments p.517 Contributed by Falcon Rappaport & Berkman LLP

SPAIN Law and Practice p.426 Contributed by act legal

4 CHAMBERS.COM

INTRODUCTION Contributed by: Caroline Silberztein, Baker McKenzie Baker McKenzie is a premier global law firm recog - nised for its vast international footprint and deep- rooted sector expertise. With more than 70 offices across over 40 jurisdictions, the firm offers clients seamless access to legal services in virtually every major market. This extensive reach enables it to sup - port cross-border transactions, regulatory matters, and complex disputes with agility and precision.

Contributing Editor

Caroline Silberztein heads Baker McKenzie's international tax and transfer pricing practice in France. She assists multinational clients in risk assessment and management, the design and implementation of

transfer pricing policies adapted to their business models, the drafting of documentation, as well as tax audits, litigation, mutual agreement procedures / arbitration and advance pricing agreements, both locally and globally.

Baker McKenzie 1 rue Paul Baudry 75008 Paris France Tel: + 33 1 4417 5300 Fax: + 33 1 4417 4575

5 CHAMBERS.COM

INTRODUCTION Contributed by: Caroline Silberztein, Baker McKenzie

International Tax 2026 – Introduction The international tax environment in 2026 is charac - terised by a sustained tension between convergence and fragmentation. On the one hand, unprecedented multilateral co-ordination efforts continue to reshape domestic tax systems and corporate tax governance. On the other hand, divergent policy choices, geopoliti - cal considerations and differing stages of legislative implementation contribute to an increasingly com - plex and uneven international tax landscape. These dynamics directly affect the way multinational enter - prises structure their operations, manage risk and approach cross–border investment. The first area of convergence lies in the progressive implementation of the OECD/G20 Inclusive Frame - work reforms. Over recent years, the global minimum tax under Pillar Two moved from policy design to operational reality in a growing number of jurisdic - tions. Many countries, including a significant number of EU member states and other major economies, have enacted domestic legislation and issued admin - istrative guidance, while others are still refining their implementation frameworks. As a result, multinational groups are increasingly required to navigate detailed domestic rules governing effective tax rates, compli - ance obligations and interaction with existing corpo - rate income tax regimes. This development has prac - tical implications well beyond tax rates, extending to internal governance, systems, data management and reporting capabilities. By contrast, Pillar One continues to raise complex political and technical questions. While consensus emerged around Amount B as a mechanism to simplify the remuneration of baseline marketing and distribu - tion activities, the future of Amount A remains uncer - tain. Ongoing discussions reflect competing objec - tives relating to the reallocation of taxing rights, the treatment of highly digitalised business models and the co-ordination (or withdrawal) of unilateral digital services taxes. As a result, multinational businesses must closely monitor developments across jurisdic - tions, where domestic approaches to digital taxation and treaty policy may continue to diverge. Beyond these global reforms, traditional international tax concepts are being tested by structural changes to

the way business is conducted. Increased digitalisa - tion and the normalisation of remote and cross-border working arrangements challenge established notions of territoriality, tax residence and permanent establish - ment. Jurisdictions have responded unevenly to these developments, with some issuing targeted guidance or adapting domestic rules, while others continue to rely on existing frameworks. At the same time, tax authorities are making intensified use of expanded reporting and exchange-of-informa - tion mechanisms. Automatic exchanges, enhanced disclosure regimes and the use of data analytics have significantly increased the ability of administrations to identify, assess and challenge perceived tax risks. Scrutiny is particularly pronounced in areas such as transfer pricing, permanent establishment exposure, withholding taxes and the taxation of mobile capital and labour. This enforcement-focused environment underscores the importance of robust documentation, proactive compliance strategies and a clear under - standing of domestic anti-avoidance and anti-evasion frameworks, including penalty and sanction regimes. Against this backdrop, dispute prevention and resolu - tion mechanisms have assumed heightened impor - tance. Advance pricing agreements, co-operative compliance programmes and tax rulings are increas - ingly used in some jurisdictions to secure upfront tax certainty, while mutual agreement procedures and arbitration play a central role in resolving cross-border disputes where conflicts arise. However, the availabil - ity, efficiency and effectiveness of these tools continue to vary significantly across countries, depending on local procedural rules and administrative practice. This Guide seeks to capture these developments through a structured, jurisdiction-by-jurisdiction analysis. Each chapter follows a common framework, addressing the sources and hierarchy of international tax law, the principles of territoriality, residence and permanent establishment, the taxation of cross-bor - der income, the implementation of global tax reforms, anti-avoidance measures, penalties and sanctions relating to international tax matters, administrative co- operation and dispute prevention/resolution mecha - nisms. By combining this consistent structure with detailed local insight, the Guide provides practition -

6 CHAMBERS.COM

INTRODUCTION Contributed by: Caroline Silberztein, Baker McKenzie

ers, in-house tax teams and policy stakeholders with a comparative overview of how international tax rules are evolving in practice across jurisdictions, at a time of significant transformation of the global tax order.

7 CHAMBERS.COM

ARGENTINA

Brazil

Paraguay

Chile

Uruguay

Buenos Aires

Argentina

Law and Practice Contributed by: Daniel Rinci, Tomas Cabanelas, Fernando García and Marisa Majul Rinci & Asociados

Contents 1. Sources and Principles p.10 1.1 Domestic Sources of International Tax Law p.10 1.2 Hierarchy of Sources p.10 1.3 OECD Model/United Nations Influence on Treaty Practice p.11 1.4 Multilateral Instrument p.11 2. Territoriality, Residence and Permanent Establishment p.11 2.1 General Principle of Territorial Taxation p.11 2.2 Tax Residence of Individuals p.11 2.3 Taxation of Resident Individuals p.12 2.4 Taxation of Non-Resident Individuals p.12 2.5 Tax Residence of Legal Entities p.12 2.6 Definition of Permanent Establishment p.12 3. Taxation of Cross-Border Income p.13 3.1 Income From Immovable Property p.13 3.2 Business Profits p.13 3.3 Passive Income p.13 3.4 Capital Gains p.14 3.5 Employment Income p.14 3.6 Other Income p.14 4. OECD/G20 Global Tax Reform p.15 4.1 Pillar One – Amount B p.15 4.2 Pillar One – Amount A p.15 4.3 Pillar Two p.15 4.4 Specific Features or Deviations of Pillar Two p.15 4.5 Digital Services Tax p.15

5. Anti-Avoidance and Anti-Evasion Measures p.15 5.1 Definition and Identification of Tax Fraud, Evasion, Tax Avoidance and Abusive Schemes p.15 5.2 Anti-Avoidance Mechanisms p.15 5.3 Blacklists and Non-Cooperative Jurisdictions p.16 5.4 Reporting Obligations and Disclosure Regimes p.16 5.5 Role of Tax Authorities and Enforcement Measures p.16 6. Penalties and Sanctions p.17 6.1 Tax Penalties p.17 6.2 Criminal Penalties p.17 6.3 Interaction Between Tax and Criminal Procedures p.17 7. Administrative Co-Operation p.17 7.1 Legal Framework for Administrative Co-Operation p.17 7.2 Exchange of Information Clauses in Tax Agreements p.18 7.3 Other Forms of International Tax Collaboration p.18 8. Mutual Agreement Procedures and Arbitratio n p.18 8.1 Availability and Legal Basis p.18 8.2 Application Deadlines p.18 8.3 Mandatory Binding Arbitration p.18 9. Dispute Prevention p.19 9.1 Advance Pricing Agreements p.19 9.2 Other Mechanisms p.19

8 CHAMBERS.COM

ARGENTINA Law and Practice Contributed by: Daniel Rinci, Tomas Cabanelas, Fernando García and Marisa Majul, Rinci & Asociados

Rinci & Asociados is a team of professionals, ac - countants and lawyers, with over 20 years of expe - rience in accounting services, legal consulting and tax litigation. The firm has a dynamic tax department in Argentina that regularly advises domestic and in - ternational clients in the agro-industrial, transporta - tion and financial sectors, as well as private clients. The firm not only advises and litigates from a legal perspective, but also takes a holistic approach to - wards taxes. For this, it relies on a team of lawyers,

accountants and tax-related collaborators who work together to provide an all-encompassing taxation and tax compliance service, which requires a deep understanding not just of applicable regulations and case law, but also of accounting, the tax authorities’ modus operandi and software applications, tax crimi - nal law, etc. The legal team has experience in double taxation, tax planning, and payroll taxes, as well as tax claims before federal and provincial authorities.

Authors

Daniel Rinci is a certified public accountant and lawyer, with a master’s in tax law. His extensive experience in tax matters, and his dual professional vision as an accountant and lawyer, have allowed

Fernando García is a certified public accountant and has been a partner at Rinci & Asociados since 2012, single-handedly leading the accounting department. After several years of experience, he has

him to work on various types of litigation, including before the National Supreme Court of Justice. In 2001 he founded Rinci & Asociados to provide advice to various companies with the conviction that teamwork, proactivity and clear and honest communication with the client were the path to successful service provision.

developed a high level of technical knowledge, the product of consistent training and updating. He provides a unique perspective to agricultural companies. Marisa Majul is a certified public accountant who has a degree in international commerce, and a master’s in finance and tax law. At Rinci & Asociados, she generates key information for decision-making through the design and development of indicators and dashboards. Marisa also has extensive experience in internal processes control and achievement of objectives.

Tomas Cabanelas graduated from the University of Buenos Aires with a focus on tax law. He then completed postgraduate studies in economic criminal law (UBA) and a master’s in criminal law (Universidad Austral),

with specialisations in wealth management, organisation and protection of assets, family planning, stock investments, finance and accounting. In addition to his role at Rinci & Asociados, he is an assistant teacher in the master’s in tax law degree course at the Universidad Católica Argentina and an assistant teacher in the introduction to tax law course at the Argentine Association of Fiscal Studies (AAEF).

CHAMBERS.COM

ARGENTINA Law and Practice Contributed by: Daniel Rinci, Tomas Cabanelas, Fernando García and Marisa Majul, Rinci & Asociados

Rinci & Asociados Estudio Rinci & Asociados Av. Santa Fe 830 - 2° Floor Buenos Aires Argentina Tel: +54 011 5031-8980 Email: Info@estudiorinci.com Web: www.estudiorinci.com

1. Sources and Principles 1.1 Domestic Sources of International Tax Law Primary Legislation The main source of international tax law in Argentina is the Income Tax Law and its implementing decree. This statute governs the taxation of Argentine-source and foreign-source income for both residents and non-residents. The Personal Assets Tax Law and the Value Added Tax Law also contain provisions with cross-border implications. Regulatory and Administrative Sources The Federal Tax Authority ( Agencia de Recaudación y Control Aduanero or ARCA) issues general resolutions and concrete-case interpretative rulings that form a critical layer of administrative guidance. While inter - pretative rulings are not formally binding on third par - ties, they carry substantial weight in practice and are routinely followed by taxpayers and advisers. Case Law and Constitutional Principles Argentine courts, including the Supreme Court of Justice, have developed a body of constitutional tax jurisprudence centred on the principles of legality (no tax without law), equality, non-confiscation and ability to pay. The economic reality doctrine (or substance over form) codified in the Tax Procedure Law allows the authorities to look through form to substance in interpreting transactions.

Treaty Network Argentina has concluded 23 comprehensive double tax treaties (DTTs), currently in force, with countries including Germany, Australia, Austria, Belgium, Boliv - ia, Brazil, Canada, Chile, Denmark, Finland, France, Italy, the Netherlands, Norway, Russia, Spain, Swe - den, Switzerland, the UAE, and the United King - dom. Argentina has also entered into tax information exchange agreements (TIEAs) with several jurisdic - tions. The treaty network is relatively modest in scope compared to those of OECD member states, but con - In Argentina’s constitutional framework, international treaties – once ratified and incorporated – have supra- legal status; that is, they rank above ordinary legisla - tion but below the National Constitution. This hierar - chy, established in the Constitution, means that where a tax treaty conflicts with domestic tax law, the treaty generally prevails. tinues to expand gradually. 1.2 Hierarchy of Sources Domestic tax law’s hierarchy starts with congres - sional laws, which are then regulated by presidential decrees. ARCA’s regulations are legally subordinate to both treaties and statutes. However, its officials will uphold the provisions contained in the organism’s res - olutions without questioning potential conflicts with superior legislation. Thus, given the practical impor - tance of regulatory resolutions in day-to-day compli - ance, taxpayers must monitor these closely alongside statutory law.

10 CHAMBERS.COM

ARGENTINA Law and Practice Contributed by: Daniel Rinci, Tomas Cabanelas, Fernando García and Marisa Majul, Rinci & Asociados

2. Territoriality, Residence and Permanent Establishment

1.3 OECD Model/United Nations Influence on Treaty Practice Argentina is not an OECD member, though it partici - pates in the OECD’s Base Erosion and Profit Shifting (BEPS) Inclusive Framework. Argentina’s treaty prac - tice draws on both the OECD Model Tax Convention and the UN Model Double Taxation Convention, with a general preference for the latter given its greater source-state taxation orientation – consistent with Argentina’s position as a capital-importing country. Notable deviations from the OECD Model include broader definitions of royalties and expanded source- state taxing rights over technical services fees (which Argentina historically treats as royalties or similar remuneration subject to withholding). Argentina has generally resisted the OECD’s narrower interpretation of the permanent establishment (PE) concept and has maintained source-based taxing rights in line with UN Model preferences. Argentina’s domestic law also imposes withholding taxes on certain payments to non-residents that may not align with treaty-reduced rates, unless the tax - payer actively invokes the applicable convention and complies with its local regulations. 1.4 Multilateral Instrument Argentina signed the OECD Multilateral Convention to Implement Tax Treaty-Related Measures to Pre - vent Base Erosion and Profit Shifting (the “Multilateral Instrument” or MLI). It has been ratified and it came into force on 1 January 2026. Argentina has opted into the MLI’s provisions on hybrid mismatch arrangements, treaty abuse (adopt - ing the Principal Purpose Test as its minimum stand - ard for satisfying the BEPS Action 6 requirement), and dispute resolution. It has made reservations on man - datory binding arbitration under Article 18. The MLI is modifying a number of Argentina’s covered tax agree - ments, though the precise treaties affected depend on the matching positions of counterparty states. Tax - payers and practitioners should review the MLI syn - thesised texts for each relevant treaty to determine the applicable rules.

2.1 General Principle of Territorial Taxation Argentina operates a worldwide taxation system for tax residents – both individuals and legal entities – meaning that Argentine tax residents are subject to income tax on income derived from all sources, whether Argentine or foreign. Non-residents, by contrast, are taxed only on Argen - tine-source income. The concept of Argentine-source income is defined broadly in the Income Tax Law to include income from assets located, placed, or used economically in Argentina; income from activities car - ried out in Argentina; and income from acts performed in Argentina, regardless of the nationality or residence of the parties, or the location where contracts were concluded. Certain special regimes apply to income from financial instruments, international transportation, and news agencies, which have their own source rules. There are no special territorial regimes for particular geo - graphic areas within Argentina that would materially alter these principles, though certain provinces and the City of Buenos Aires impose their own provincial- level taxes – turnover tax – with their own territorial rules. 2.2 Tax Residence of Individuals Under the Income Tax Law, individuals are considered Argentine tax residents if they meet any of the follow - ing criteria: • Argentine nationality – Argentine nationals are gen - erally tax residents unless they have acquired for - eign residence status through the effective change of domicile abroad under the conditions specified in the law. • Foreign nationals with permanent residence – foreign nationals who have obtained permanent residence status in Argentina under immigration law are considered tax residents from the date they obtain such status. • Presence test – foreign nationals who remain in Argentina for 12 months during any consecutive 12-month period are also treated as tax residents,

11 CHAMBERS.COM

ARGENTINA Law and Practice Contributed by: Daniel Rinci, Tomas Cabanelas, Fernando García and Marisa Majul, Rinci & Asociados

with certain exceptions for temporary assignments and diplomatic personnel. Once an individual qualifies as a tax resident, that sta - tus is maintained until residence is formally lost. Loss of residence occurs when the individual acquires per - manent residence in a foreign country or is continu - ously absent from Argentina for more than 12 months, subject to specific procedural requirements including notification to tax authorities. 2.3 Taxation of Resident Individuals Argentine tax residents are subject to income tax on their worldwide income at progressive rates. The Income Tax Law schedules income into four catego - ries: • income from capital (rentals, interests); • income from going concerns (business income); • income from work in a dependency relationship (employment); and • income from independent personal services (self- employment and professional fees). Progressive income tax rates for individuals currently range from 5% to 35%, applied on net taxable income after allowable deductions and personal allowances. Resident individuals must also include foreign-source income in their annual income tax return and may claim a foreign tax credit for taxes paid abroad on that income, subject to per-country and overall limitations. Special schedular rates apply to certain categories of income. Financial income – including interest on bank deposits, dividends from Argentine companies, and capital gains on financial instruments – is taxed at a flat rate of 5% or 15% depending on the currency denomination. 2.4 Taxation of Non-Resident Individuals Non-resident individuals are subject to Argentine income tax exclusively on Argentine-source income. The mechanism for taxing non-residents is generally through withholding at source, administered by the Argentine payer who acts as the withholding agent. The Income Tax Law establishes presumptive net income percentages for various categories of pay -

ment made to non-residents, to which the maximum individual rate of 35% is then applied. The effective withholding rates thus vary by income type. For exam - ple: • Royalties and technical fees – typically subject to withholding tax on a presumed net income base, yielding effective rates of approximately 12.25% to 21% depending on the type of service. • Interest payments – subject to withholding tax at effective rates ranging from 15.05% to 35%, depending on the nature of the lender and the loan. • Dividends – distributed dividends are subject to a 7% withholding tax. • Services rendered abroad but economically used in Argentina – subject to withholding tax under the technical services rules. Treaty protection may reduce or eliminate withhold - ing tax on specific income categories where Argentina has concluded a relevant double tax agreement. 2.5 Tax Residence of Legal Entities Legal entities – including local corporations and branches of foreign entities – are considered Argen - tine tax residents if they are incorporated or organ - ised under Argentine law. Foreign entities incorpo - rated abroad are not considered Argentine residents, regardless of where their management and control are exercised, unless they have a branch or permanent establishment in Argentina, in which case, the branch/ PE is taxed on the Argentine-source income attribut - able to it. Argentine-resident companies are subject to corpo - rate income tax on worldwide income. The corporate tax rate is currently 35% for taxable income exceed - ing certain thresholds, with a reduced rate of 25% for lower income brackets. 2.6 Definition of Permanent Establishment Domestic Definition The domestic definition of PE is set out in the Income Tax Law and the implementing regulations. A PE is generally defined as a fixed place of business through which a non-resident entity carries out all or part of its activities in Argentina. The definition encompasses branches, agencies, offices, factories, workshops and

12 CHAMBERS.COM

ARGENTINA Law and Practice Contributed by: Daniel Rinci, Tomas Cabanelas, Fernando García and Marisa Majul, Rinci & Asociados

installations, as well as construction or assembly pro - jects lasting more than six months. The domestic law also provides for a dependent agent PE, where a person acting on behalf of a foreign enter - prise habitually concludes contracts or plays the prin - cipal role in the conclusion of contracts in Argentina without material modification by the enterprise. Deviations From Treaty Definitions Argentina’s domestic PE definition is broadly consist - ent with the OECD Model in structure, though some of Argentina’s older treaties retain features that are more closely aligned with the UN Model, including the force-of-attraction principle – under which, profits attributable to a PE include not only those directly generated by the PE’s activities but also income from goods sold or activities of the same or similar kind to those carried out through the PE. This principle was abandoned by the OECD Model but is retained in some bilateral treaties. Argentina’s treaties generally do not include the anti- fragmentation rules introduced in the OECD’s 2017 Model update (following BEPS Action 7), except where treaties have been modified through the MLI. The domestic rules similarly pre-date these develop - ments, meaning that sophisticated fragmentation of activities may still present opportunities in certain treaty contexts, though the substance requirements under the general anti-avoidance framework limit this in practice. 3. Taxation of Cross-Border Income 3.1 Income From Immovable Property Residents Argentine resident individuals and companies are taxed on income derived from immovable property located in Argentina as part of their worldwide income. Rental income of individuals is subject to the progres - sive rates described above, except when derived from residential property, which was recently exempted by a tax reform passed in March 2026. For companies, rental income is included in ordinary taxable income subject to corporate tax. Capital gains arising from

the sale of Argentine real estate by individuals are now exempt under the same reform. Non-Residents Non-residents receiving rental income from Argen - tine real estate are subject to withholding tax. The presumed net income percentage applied under the domestic rules is 60% of gross rent, to which the 35% rate is applied, resulting in an effective withholding rate of 21%. Capital gains realised by non-residents on the sale of Argentine immovable property are sub - ject to a 15% tax on the net gain. The exemption on capital gains and rental income arising from residential real estate applies to non-residents as well. 3.2 Business Profits Argentine-resident entities are subject to corporate income tax on worldwide business profits at the appli - cable corporate rates (25% or 35% depending on the income bracket). Expenses necessary to obtain, maintain and preserve taxable income are generally deductible, subject to specific limitations (eg, on inter - est deductibility, on payments to related parties in low- tax jurisdictions, and on the deductibility of royalties). Non-resident entities carrying on business through a PE in Argentina are taxed only on profits attributable to the PE. The attribution of profits to PEs follows the functionally separate entity approach, though Argen - tina’s rules in this area are less developed than those of many OECD members and administrative guidance plays an important role. The force-of-attraction princi - ple mentioned in 2.6 Definition of Permanent Estab - lishment applies under certain older treaties. Argentina does not currently have a comprehensive participation exemption for dividends received from foreign subsidiaries by Argentine parent companies, though the foreign tax credit mechanism partially miti - gates double taxation of foreign-source income. 3.3 Passive Income Dividends Dividends paid by Argentine companies to non-resi - dent shareholders are subject to a 7% withholding tax on distributions.

13 CHAMBERS.COM

ARGENTINA Law and Practice Contributed by: Daniel Rinci, Tomas Cabanelas, Fernando García and Marisa Majul, Rinci & Asociados

Interest Domestic withholding tax on interest paid to non-res - idents varies significantly depending on the nature of the recipient and the loan. Interest paid to qualifying foreign financial entities is taxed at an effective rate of 15.05%, while interest paid to other non-resident lenders is taxed at a rate of 35%. Royalties Royalties paid to non-residents are subject to with - holding tax at effective rates that range from approx - imately 12.25% to 28%, depending on the type of intellectual property and the contractual arrangement. Domestic rules treat a broad range of technical assis - tance, technology transfer, and know-how payments as royalties. Treaty provisions may reduce these rates, and Argentina’s treaties generally define royalties broadly, consistent with the UN Model. 3.4 Capital Gains Resident individuals are subject to a flat 15% rate on gains from the disposal of shares, bonds and other securities denominated in foreign currency or in local currency with an adjustment clause, and a 5% rate on gains from instruments denominated in Argen - tine pesos without an adjustment clause. Corporate taxpayers include capital gains in ordinary taxable income, subject to the applicable corporate rates. Capital gains on the sale of listed shares is exempt. Non-residents realising capital gains on Argentine- source assets are subject to withholding tax under the same presumptive income framework applicable to other passive income. Gains on Argentine real estate, shares of Argentine companies, and certain financial instruments are all within scope. Many of Argentina’s treaties contain provisions that preserve source-state taxation rights over capital gains on shares, the value of which derives principally from immovable property, consistent with OECD and UN Model approaches. 3.5 Employment Income General Rules Employment income received by Argentine tax residents is taxable at different rates according to bracket. Employers are required to withhold income tax from salary payments on a monthly basis. Resi - dent employees are taxed on worldwide employment

income, with a foreign tax credit available for taxes withheld abroad. Short-Term Assignments and Cross-Border Employment For individuals who are not Argentine tax residents but perform employment activities in Argentina, Argentine-source employment income is subject to withholding tax. The domestic rules follow a source approach based on the place where the work is physi - cally performed, meaning that compensation for ser - vices physically rendered in Argentina is treated as Argentine-source, regardless of where the contract is concluded or payment is made. Argentina’s tax treaties generally follow the OECD Model Article 15 approach, under which remunera - tion may be taxed in the state where employment is exercised. Remote Working Argentina has not enacted specific legislation address - ing the international tax treatment of remote work arrangements. In practice, the existing source rules apply: services performed remotely from Argentina by an Argentine resident for a foreign employer are treated as foreign-source employment income (since the work is performed in Argentina but for a foreign entity – the characterisation depends on the relevant treaty). Conversely, services performed remotely from abroad by a non-resident for an Argentine employer are generally not considered Argentine-source under the domestic rules. This area lacks specific regulatory guidance and continues to evolve in practice. 3.6 Other Income A noteworthy feature of Argentine international tax law is the treatment of fees for technical services paid to non-residents. Unlike many OECD Model-based sys - tems in which technical service fees are treated as business profits (Article 7) rather than royalties (Article 12), Argentina’s domestic law characterises technical services payments as subject to withholding tax as though they were royalties. This broad treatment of technical services has been a source of treaty conflict in a number of cases.

14 CHAMBERS.COM

ARGENTINA Law and Practice Contributed by: Daniel Rinci, Tomas Cabanelas, Fernando García and Marisa Majul, Rinci & Asociados

4. OECD/G20 Global Tax Reform 4.1 Pillar One – Amount B As a member of the OECD/G20 Inclusive Framework, Argentina participated in the negotiations that pro - duced the Amount B framework for simplifying the application of the arm’s length principle to baseline marketing and distribution activities. At the time of writing, Argentina has not yet formally incorporated Amount B into domestic law or regulations. 4.2 Pillar One – Amount A Argentina has constructively engaged in the Pillar One Amount A negotiations through its participation in the Inclusive Framework. As a significant develop - ing economy and capital-importing country, Argen - tina’s interest in Amount A is primarily to ensure that it receives a fair allocation of taxing rights over the profits of large multinational digital and consumer- facing enterprises that generate significant revenue from Argentine users and consumers without having a physical presence in Argentina. 4.3 Pillar Two Argentina has not yet implemented the OECD’s Global Anti-Base Erosion (GloBE) rules – the Income Inclu - sion Rule, Undertaxed Profits Rule, and Qualified Domestic Minimum Top-up Tax under Pillar Two. At the time of writing, there is no enacted legislation or draft bill before congress introducing Pillar Two rules into Argentine domestic law. 4.4 Specific Features or Deviations of Pillar Two As Argentina has not implemented Pillar Two, there are no domestic deviations to report at this stage. 4.5 Digital Services Tax Argentina does not have a standalone national digital services tax. However, the Argentine VAT system was extended to cover digital services supplied by non- resident providers to Argentine consumers through “reverse charge” and “payment intermediary” mecha - nisms. Under these rules, non-resident providers of digital services (including streaming, software, online advertising, and platform-based services) are required to register and collect VAT at the standard 21% rate on services supplied to Argentine final consumers,

with payment facilitated through Argentine credit and debit card processors where direct registration is not effected. Several Argentine provinces have also applied provin - cial turnover tax to digital services rendered by foreign providers. These provincial-level taxes add a layer of complexity for non-resident digital businesses operat - ing in Argentina. 5. Anti-Avoidance and Anti-Evasion Measures 5.1 Definition and Identification of Tax Fraud, Evasion, Tax Avoidance and Abusive Schemes Tax Evasion and Fraud Argentina’s Criminal Tax Regime establishes mini - mum thresholds to consider tax fraud a criminal offence. Simple tax fraud is a criminal offence when the amount of evaded tax exceeds ARS100 million (roughly USD70,000) per tax and per fiscal period, punishable by imprisonment from two to six years. Aggravated tax evasion – which includes the use of false invoices, interposed persons, tax havens or much larger amounts evaded – carries penalties of three-and-a-half to nine years’ imprisonment. Tax Avoidance and the Economic Reality Doctrine The general anti-avoidance rule in Argentina is pri - marily the economic reality doctrine. This doctrine permits the tax authority to recharacterise transac - tions in accordance with their true economic nature, disregarding legal forms that do not reflect economic substance. The doctrine has been applied extensive - ly in cross-border contexts to challenge structures involving treaty shopping, artificial PE fragmentation, and the use of offshore holding companies without business substance. 5.2 Anti-Avoidance Mechanisms Transfer Pricing Rules Argentina introduced comprehensive transfer pricing legislation in 1998, applying the arm’s length principle to transactions between related parties and to trans - actions with entities in low-tax jurisdictions (regardless of whether the parties are formally related). The rules

15 CHAMBERS.COM

ARGENTINA Law and Practice Contributed by: Daniel Rinci, Tomas Cabanelas, Fernando García and Marisa Majul, Rinci & Asociados

generally follow OECD Guidelines, with five transfer pricing methods available: comparable uncontrolled price, resale price, cost plus, profit split, and transac - tional net margin method. The sixth method – a spe - cific rule for commodity transactions using publicly quoted prices on a reference date – is a notable fea - ture of Argentine law with no direct OECD equivalent and has been a significant source of controversy in the agribusiness sector. Controlled Foreign Corporation (CFC) Rules Argentina enacted specific and complicated CFC rules that entered into effect in 2019. Argentine resi - dents holding foreign interests must, in some cases, include their proportionate share of the foreign entity’s income in their Argentine taxable income on a current accrual basis, regardless of whether the income has been distributed. Some of the applicable parameters that may trigger this obligation are, among others: holding at least 50% participation in a foreign entity either directly or with relatives; effectively controlling the foreign entity; the foreign entity being subject to low taxation; or the foreign entity earning more than 50% of its income from passive sources. 5.3 Blacklists and Non-Cooperative Jurisdictions Argentina maintains a list of non-cooperative and low-tax jurisdictions for tax purposes. A jurisdiction is classified as non-cooperative if it has not entered into effective information exchange arrangements with Argentina. A jurisdiction is classified as low tax if its applicable corporate tax rate is less than 60% of the lowest Argentine corporate rate. Currently, this thresh - old applies where a jurisdiction’s corporate tax rate is lower than 15%. Transactions with entities located in non-cooperative or low-tax jurisdictions attract the following conse - quences: • interest payments are subject to higher withholding rates; • payments to service providers are generally non- deductible unless the taxpayer can demonstrate

the genuine economic nature of the service and its market price; • the CFC rules apply more broadly; and • certain anti-deferral rules come into effect for income channelled through such jurisdictions. 5.4 Reporting Obligations and Disclosure Regimes Financial Account Reporting (CRS/FATCA) Argentina has implemented the OECD’s Common Reporting Standard (CRS) for automatic exchange of financial account information and is an active partici - pant in the global CRS exchange network. Argentina also has an intergovernmental agreement (IGA) with the United States for FATCA compliance (under the Foreign Account Tax Compliance Act), according to which Argentine financial institutions report informa - tion on US account holders to local tax authorities for onward transmission to the IRS. The US also provides information to Argentina, although with a more limited scope. Treaty Network Several treaties provide for request-based tax infor - mation requests, which synergises with CRS/FATCA automatic reporting, often used by tax authorities to broaden the scope of information received automati - cally for tax assessments and criminal prosecution. 5.5 Role of Tax Authorities and Enforcement Measures Federal tax authorities hold wide power to investigate tax fraud, such as: • Access to books and records – Inspectors may require the production of accounting records, contracts, banking documents and any other documentation relevant to the determination of tax liability. Taxpayers are required to maintain records for a period of ten years. • Tax audits – Both desk audits and field audits are routinely conducted. Large taxpayers are subject to permanent oversight by a dedicated large taxpayer division. • Unannounced visits – In certain circumstances, inspectors may conduct unannounced visits to business premises to verify compliance with invoic - ing and registration obligations.

16 CHAMBERS.COM

ARGENTINA Law and Practice Contributed by: Daniel Rinci, Tomas Cabanelas, Fernando García and Marisa Majul, Rinci & Asociados

6.2 Criminal Penalties Criminal liability can extend to directors, officers, and managers of legal entities who participated in or authorised the evasion. Legal entities themselves can be subject to administrative sanctions, including fines, suspension of tax registrations, and the loss of tax benefits. 6.3 Interaction Between Tax and Criminal Procedures The Tax Penal Regime requires the tax assessment to be issued by tax authorities before criminal charges can be filed; the tax authority files a criminal case once the relevant thresholds and indicators are met and the administrative audit discloses potential criminal conduct. However, the tax assessment may be appealed to the courts and this may run concurrently with criminal pro - cedures. The exception is monetary fines imposed by the tax authorities, which are deferred until the crimi - nal case is settled. Co-ordination between tax authorities and the judi - ciary is maintained through inter-institutional agree - ments and joint working protocols. The courts may also order precautionary measures – such as asset freezes – at the request of the prosecution in signifi - cant tax fraud cases. 7. Administrative Co-Operation 7.1 Legal Framework for Administrative Co- Operation Argentina’s international administrative co-operation in tax matters rests on several legal instruments: • OECD Multilateral Convention on Mutual Admin - istrative Assistance in Tax Matters (MAC) – Argen - tina signed and ratified the MAC. This convention provides the broadest legal basis for information exchange, including automatic, spontaneous, and on-request exchange, as well as the possibility of joint audits. • Bilateral tax treaties – Argentina’s double tax treaties all include provisions on the exchange of

• Fiscal raids – For criminal tax cases, search and seizure operations may be conducted with the intervention of the Public Prosecutor’s Office and, where applicable, the federal police. • Information requests – Information may be request - ed from third parties, including banks and financial institutions, under the bank secrecy lifting ( levan- tamiento del secreto bancario ) mechanism avail - able in tax investigation proceedings. • International co-operation – Federal tax authorities may request information from foreign tax authori - ties through the exchange of information mecha - nisms in Argentina’s tax treaties and TIEAs, as well as through the OECD Multilateral Convention framework. 6. Penalties and Sanctions 6.1 Tax Penalties The main administrative penalties applicable to cross- border transactions include: • omission penalty – a fine of 100% of the unpaid tax for failure to pay taxes on time, rising to 200% when the omission relates to cross-border transac - tions or to transactions with non-cooperative or low-tax jurisdictions; • fraud penalty – a fine of between two and six times the amount of the unpaid tax for deliberate fraud, including the use of false documentation or fraudu - lent schemes in cross-border contexts; • formal infractions – fines for failure to comply with formal obligations (such as filing returns, maintain - ing documentation, and responding to information requests) where previously negligible, have been substantially raised; and • transfer pricing penalties – specific penalties apply for failure to file transfer pricing documentation or for filing documentation that is incomplete or incor - rect. The courts ultimately rule on the validity of the pen - alties imposed by tax authorities and, once ruled, a different court enforces them.

17 CHAMBERS.COM

ARGENTINA Law and Practice Contributed by: Daniel Rinci, Tomas Cabanelas, Fernando García and Marisa Majul, Rinci & Asociados

8. Mutual Agreement Procedures and Arbitration 8.1 Availability and Legal Basis Argentina provides for the use of mutual agreement procedures (MAPs) under the MAP articles of its bilat - eral tax treaties, which generally follow Article 25 of the OECD or UN Model. Argentina has also implemented the minimum stand - ard on MAP under BEPS Action 14, committing to resolve MAP cases in a timely and effective man - ner. The country has published its MAP profile on the OECD website, which sets out its policies and procedures for initiating, processing, and resolving MAP cases. Argentina’s MAP programme is relatively nascent compared to those of OECD members, and the volume of MAP cases handled by the competent authority remains modest. 8.2 Application Deadlines Under most of Argentina’s treaties, a MAP request must be submitted within three years of the first notification of the action giving rise to taxation not in accordance with the treaty – consistent with the OECD Model Article 25 (1) standard. Some older trea - ties contain shorter limitation periods. Under Argen - tina’s domestic MAP guidance, requests must be submitted to the competent authority in writing with sufficient information to identify the taxpayer, the rel - evant treaty, the transactions at issue, and the basis Argentina has not opted into mandatory binding arbi - tration under the MLI (Article 18) and has not included binding arbitration clauses in its bilateral tax treaties. This means that MAP resolution remains subject to the political will of both competent authorities, with no guaranteed mechanism for final resolution if they cannot reach agreement. Argentina’s position reflects a broader reluctance among many developing and emerging economies to accept mandatory arbitration, given concerns about sovereignty, the costs of arbitration proceedings, and the perception that arbitration panels may not give sufficient weight to developing-country perspectives. for the claim of treaty non-compliance. 8.3 Mandatory Binding Arbitration

information, broadly modelled on Article 26 of the OECD or UN Model. • Tax information exchange agreements – Argentina has entered into TIEAs with a number of jurisdic - tions, particularly offshore financial centres, where no comprehensive DTT exists. • CRS competent authority agreements – Argentina has entered into multilateral automatic exchange of financial account information under the CRS framework. 7.2 Exchange of Information Clauses in Tax Agreements Argentina participates in all three standard modalities of information exchange: • On-request exchange – Argentina may request specific information from treaty partners relating to identified taxpayers or transactions, and must respond to incoming requests from foreign compe - tent authorities within the standard timeframes. • Automatic exchange – Argentina exchanges finan - cial account information automatically under the CRS framework with over 100 jurisdictions annu - ally. FATCA exchange with the United States also occurs on an automatic basis under the IGA. • Spontaneous exchange – Argentina may spontane - ously transmit information to foreign tax authorities when it becomes aware of information likely to be of interest to those authorities, consistent with the MAC and applicable treaty obligations. Argentina has largely met the international stand - ard for effective exchange of information and has received satisfactory ratings in OECD Global Forum peer reviews. 7.3 Other Forms of International Tax Collaboration Argentina actively participates in the OECD/G20 Inclusive Framework on BEPS, attending meetings and contributing to the development of internation - al standards. This participation provides a channel for technical collaboration with other tax authorities beyond formal legal instruments.

18 CHAMBERS.COM

Page i Page 1 Page 2 Page 3 Page 4 Page 5 Page 6 Page 7 Page 8 Page 9 Page 10 Page 11 Page 12 Page 13 Page 14 Page 15 Page 16 Page 17 Page 18 Page 19 Page 20 Page 21 Page 22 Page 23 Page 24 Page 25 Page 26 Page 27 Page 28 Page 29 Page 30 Page 31 Page 32 Page 33 Page 34 Page 35 Page 36 Page 37 Page 38 Page 39 Page 40 Page 41 Page 42 Page 43 Page 44 Page 45 Page 46 Page 47 Page 48 Page 49 Page 50 Page 51 Page 52 Page 53 Page 54 Page 55 Page 56 Page 57 Page 58 Page 59 Page 60 Page 61 Page 62 Page 63 Page 64 Page 65 Page 66 Page 67 Page 68 Page 69 Page 70 Page 71 Page 72 Page 73 Page 74 Page 75 Page 76 Page 77 Page 78 Page 79 Page 80 Page 81 Page 82 Page 83 Page 84 Page 85 Page 86 Page 87 Page 88 Page 89 Page 90 Page 91 Page 92 Page 93 Page 94 Page 95 Page 96 Page 97 Page 98 Page 99 Page 100 Page 101 Page 102 Page 103 Page 104 Page 105 Page 106 Page 107 Page 108 Page 109 Page 110 Page 111 Page 112 Page 113 Page 114 Page 115 Page 116 Page 117 Page 118 Page 119 Page 120 Page 121 Page 122 Page 123 Page 124 Page 125 Page 126 Page 127 Page 128 Page 129 Page 130 Page 131 Page 132 Page 133 Page 134 Page 135 Page 136 Page 137 Page 138 Page 139 Page 140 Page 141 Page 142 Page 143 Page 144 Page 145 Page 146 Page 147 Page 148 Page 149 Page 150 Page 151 Page 152 Page 153 Page 154 Page 155 Page 156 Page 157 Page 158 Page 159 Page 160 Page 161 Page 162 Page 163 Page 164 Page 165 Page 166 Page 167 Page 168 Page 169 Page 170 Page 171 Page 172 Page 173 Page 174 Page 175 Page 176 Page 177 Page 178 Page 179 Page 180 Page 181 Page 182 Page 183 Page 184 Page 185 Page 186 Page 187 Page 188 Page 189 Page 190 Page 191 Page 192 Page 193 Page 194 Page 195 Page 196 Page 197 Page 198 Page 199