Argentina’s ratification of the BEPS Multilateral Instrument takes effect from 1 January 2026, enabling the phased application of anti-treaty-abuse and dispute resolution measures across its covered tax treaties, subject to ratification by treaty partners.
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI) entered into force for Argentina on 1 January 2026.
Argentina signed the convention on 7 June 2017 and deposited its final MLI Position on 29 September 2025, identifying 17 tax treaties to be covered by the MLI.
For a tax treaty to fall within the scope of the MLI, both contracting jurisdictions must have joined the convention, listed each other as covered tax agreements, and deposited their respective instruments of ratification, acceptance, or approval.
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 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.
