The two countries have replaced their 1979 agreement with a modernised treaty that entered into force on 12 June 2026 and will apply from 1 January 2027.
The new income and capital tax treaty between Argentina and Austria, signed on 6 December 2019, went into effect on 12 June 2026, replacing the 1979 agreement that terminated on 1 January 2009.
The treaty governs taxation of corporate profits, dividends, interest, royalties, and capital gains across both jurisdictions.
The treaty applies to Argentine income tax and personal assets tax, alongside Austrian income tax, corporation tax, land tax, and levies on agricultural enterprises and vacant land plots. A key provision establishes that permanent establishment status applies when an enterprise supplies services through employees or personnel for more than six months within any twelve-month period.
Dividends face withholding taxes of 10% for qualifying holding companies (25% stake held for 365 days) and 15% otherwise.
Interest withholding is set at 12%, with exemptions for government-backed loans and bank-financed equipment.
Royalty rates vary: 3% for news usage, 5% for literary and artistic works, 10% for industrial and scientific equipment or patents, and 15% for other cases.
The treaty applies from 1 January 2027.
Earlier, Argentina formally ratified its income and capital tax treaty with Austria on 10 April 2026. The ratification was earlier formalised when the President of Argentina signed Decree No. 233/2026 on 9 April 2026.
