The amended Argentina-France tax treaty protocol enters into force on 22 October 2026, reducing withholding rates on dividends, interest, and royalties and expanding source-country taxation of certain capital gains from 1 January 2027.
The amended protocol to the 1979 income and capital tax treaty between Argentina and France comes into force on 22 October 2026. Argentina and France signed the protocol on 6 December 2019 as the second amendment to the original treaty. The new rules take effect from 1 January 2027 and reshape how both countries treat cross-border income flows.
The amended Argentina-France tax treaty protocol includes substantive provisions applying from 1 January 2027. It reduces dividend withholding to 10% for substantial shareholders and 15% for other recipients. Interest is generally subject to 12%, with exemptions for certain government-backed payments.
Royalty rates range from 3% to 10%, although higher rates may apply to some copyrights and unregistered technology transfers. The protocol expands source-country taxation of gains from property-rich shares and limits tax on other share gains to 10% or 15%.
An MFN clause provides access to more favourable rates agreed with third countries after 6 December 2019.
