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.
The Chamber of Deputies approved it in October 2024.
Once the internal ratification process is finalised, Argentina must submit its ratification instrument to officially bring the MLI into effect for its applicable tax treaties.
The MLI takes effect for a covered agreement on the first day of the month after three months have passed since both parties deposited their ratification instrument.
Once in force, the MLI provisions will generally apply to a covered agreement from 1 January of the year after it takes effect for withholding taxes, 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.
