Mining 2025

ARGENTINA Law and Practice Contributed by: Sebastián P. Vedoya, Sergio Arbeleche and Dolores Cattaneo, Bruchou & Funes de Rioja

leases of real estate (with some exemptions). In addition, digital services rendered from abroad to Argentine tax residents are taxed regardless of the tax status of the recipient of the services. Regarding exports of goods and services, it is considered that they are subject to a 0% VAT rate as Argentine exporters are allowed to recov - er VAT paid to their suppliers for the concepts used to manufacture exported goods or to con - duct exported services. The general VAT rate is assessed at 21%, although a reduced rate of 10.5% or an increased rate of 27% could be applicable in certain cases. RIGI provides certain VAT incentives for mining projects, including the issuance of input credit certificates for the VAT amounts invoiced to the SPVs that qualify under the promotional regime. Personal assets tax Personal assets tax is imposed on all existing assets held by Argentine resident individuals and undivided estates by December 31st of each year. Foreign individuals and undivided estates located abroad are subject to this tax exclusively on assets located in Argentina. Argentine corporate entities governed by the General Corporate Law No 19,550 are required to pay personal assets tax corresponding to their shareholders that are Argentine-resident individuals and undivided estates or foreign resident individuals or corporations, for the tax corresponding to their shares as of December 31st each year. The general rate is 0.50% and is levied on the proportional net worth value of the shares held by December 31st. Pursuant to Law 27,743, those micro, small and medium-sized entities that qualify as “compliant taxpayers” are

enabled to apply a reduced 0.375% personal assets tax rate for periods 2023, 2024 and 2025. Pursuant to the Personal Assets Tax Law, the Argentine company is entitled to seek reim - bursement of the paid tax from the applicable local individuals and/or foreign shareholders, even by withholding those amounts from any dividend distribution. Tax on credits and debits in Argentine bank accounts Tax on bank credits and debits is levied on any credit and debit in an Argentine bank account and upon other transactions which, due to their special nature and characteristics, are similar or could be used in substitution for a bank account. The general tax rate applicable is equal to 0.6% for each credit, and 0.6% for each debit. There are specific tax rates and tax exemptions appli - cable for certain cases. Taxpayers may credit a portion of the tax paid against their IT liability and may deduct the remaining amount from their IT base to the extent certain conditions are met. Excise tax Excise tax (or internal tax) is levied on producers, manufacturers or importers of goods expressly designated by the law (eg, insurance, tobacco, spirits, soft drinks, certain automobiles, motors, wine, etc), and applies to only one stage of production. The applicable rates vary accord - ing to the goods concerned and, in general, are imposed on the sales price. Import and export duties and taxes The definitive importation of goods is generally subject to the payment of import duties and other taxes (unless any exception applies, such as the one stated in the Mining Investments Law

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