The Argentinian tax administration (AFIP) issued Resolution No 3576 on 7 January 2014, which makes public the white list of cooperative jurisdictions, effective from 1 January, 2014. Countries not in the white list are to be treated as “not cooperative” for tax purposes. Argentinian law provides for measures for low- or no-tax jurisdictions that include higher withholding taxes, more restrictive transfer pricing rules and CFC rules. A so-called “60% tax” applies on all payments received from low- or no-tax jurisdictions, since it is presumed to have evaded Argentinian income tax, VAT and excise duties.
Following Decree No. 589/2013, Argentina applies a white-listing system rather than the earlier blacklisting one. Resolution No 3576 allows for a country included in the white list at the beginning of a tax year to be treated as such for the entire tax year for transfer pricing purposes.
