The Income Tax Treaty of 2015 between Argentina and Mexico was expected to enter into force on 23 August 2017, after completing the ratification procedure. The provisions of the treaty generally follow the OECD Model Tax Convention. The treaty was ratified by Argentina on 23rd November 2016 by way of Law No. 27.334 and it was published in the Official Gazette of Argentina on 21st December 2016. The treaty allows for reduced rates of withholding tax on dividends, interest, royalties, capital gains, and certain other items of income and the treaty also contains a non-discrimination clause and a provision for limitation of benefits to combat potential abuse of the treaty. This treaty provides that withholding tax (WHT) on dividends would be limited to 10% where the recipient owns 25% of the paying company and a maximum 15% rate applies for less than 25% ownership. The treaty does not give relief from the application of the Argentine equalization tax. Interest payments would be subject to a maximum 12% withholding tax rate. In the case of royalties 10% or 15% WHT would apply depending on the type of royalty (e.g., payments for the use of intangibles, certain software licenses, know-how, and technical assistance). Also, capital gains resulting from the sale of shares would be subject to 10% WHT in the case of a direct participation of at least 25% and to a 15% rate in all other cases.
Related Posts
Argentina: ARCA announces 2025 personal assets tax threshold, brackets
Argentina’s tax authority (ARCA) has updated the thresholds and brackets for the personal assets tax for individuals and undivided estates for the fiscal year ending on 31 December 2025. Minimum value applicable to valuation of assets
Read More
Mexico signs CRS MCAA addendum to expand crypto reporting
Mexico signed the Addendum to the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (CRS MCAA) on 21 November 2025. The addendum updates the Common Reporting Standard (CRS) with additional reporting
Read More
Mexico announces UMA values for 2026
Mexico has gazetted the values of the Unit of Measurement and Update (UMA) for 2026 on 9 January 2026. The UMA is a key reference used in Mexico to calculate various administrative and fiscal obligations, including fines, fees, and social
Read More
Mexico launches 2026 fiscal regularisation programme
The Tax Administration Service (SAT) of Mexico has announced on 22 January 2026 the implementation of the Fiscal Regularisation Programme 2026, targeting individuals and companies with income of up to MXN 300 million during the 2024 fiscal
Read More
Mexico: SAT clarifies proof of tax status not required for electronic invoices
Mexico’s Tax Administration Service (SAT) has confirmed, on 20 January 2026, that the Proof of Tax Status (Constancia de Situación Fiscal, CSF) is not mandatory for issuing electronic invoices (CFDI). Any issuer who conditions the issuance of a
Read More
Argentina, Vietnam conclude initial round of tax treaty talks
Officials from Argentina and Vietnam held the first round of negotiations for an income tax treaty from 12 to 16 January 2026. The aim is to prevent double taxation and tax evasion between the two jurisdictions, as well as encourage greater
Read More