Argentina issued Resolución General N°3577/2013 on 7 January 2014 that establishes a new income tax (Impuesto a las Ganancias) on transactions where goods are exported to a foreign jurisdiction other than the jurisdiction billed for the transaction. A 0.5% withholding tax now applies to exports in “triangular operations” made after 7 January 2014, while a further withholding tax of 1.5% will apply to exports to low-tax jurisdictions. The tax will be imposed only if there is an intermediary that is not the final recipient of the goods. The objective is to deter transfer pricing practices where a fictitious intermediary buys the goods for a low price, and then resells at a higher price.
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