Argentina’s President ratified the Multilateral Convention to Prevent BEPS (MLI) on 28 May 2025.
Argentina’s President has signed Decree No. 361/2025, ratifying Law No. 27.788 and the Multilateral Convention to Implement Tax Treaty Measures to Prevent BEPS (MLI), which was published in Official Gazette No. 36.175 on 28 May 2025.
Argentina submitted its provisional MLI position at signing, listing its reservations, notifications, and 17 tax treaties to be covered by the MLI.
Once in force, the MLI provisions will generally apply to a covered agreement for withholding taxes from 1 January of the year after it takes effect and for other taxes for periods starting 6 months after its effective date.
However, for Argentina’s application of the MLI to other taxes, it is reserved that the MLI will apply to tax periods starting on or after 1 January of the following six months after it enters into force.
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (“Multilateral Instrument” or “BEPS MLI”) allows governments to modify existing bilateral tax treaties in a synchronised and efficient manner to implement the tax treaty measures developed during the BEPS Project, without the need to expend resources renegotiating each treaty bilaterally.
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, after the Chamber of Deputies approved it in October 2024.
