The MLI is set to take effect in Argentina starting 1 January 2026.
Argentina officially ratified the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) by depositing its instrument of ratification on 29 September 2025.
Argentina’s MLI position, set out in its reservations and notifications filed with the ratification instrument, designates 17 tax treaties to be covered by the convention.
The MLI is set to take effect in Argentina starting 1 January 2026. However, its application to Argentina’s individual tax treaties will depend on whether the other countries involved in those agreements have also ratified the MLI.
The provisions of the MLI will typically take effect for withholding taxes from 1 January of the year after it enters into force. For those provisions coming into force on 1 January 2026, they will apply starting that same date.
For other taxes, the MLI will generally apply to taxable periods beginning after a six-month window following its entry into force. However, Argentina has made a specific reservation: for its application of the MLI to other taxes, the provisions will only apply to tax periods starting on or after 1 January of the calendar year following the six-month period after the MLI becomes effective.
The Multilateral Instrument (BEPS MLI) offers concrete solutions for governments to close loopholes in international tax treaties by transposing results from the BEPS Project into bilateral tax treaties worldwide. The BEPS MLI allows governments to implement agreed minimum standards to counter treaty abuse and to improve dispute resolution mechanisms while providing flexibility to accommodate specific tax treaty policies.
Earlier, Argentina’s Senate approved the law to ratify the Multilateral Convention on Tax Treaty Measures to Prevent Base Erosion and Profit Shifting (MLI) on 7 May 2025, following its approval by the Chamber of Deputies in October 2024.
