Argentina has amended its income tax provisions relating to securities transactions and dividend distributions. Key changes include a 15% tax on gains from selling securities, a 13.5% tax on foreign shareholders' security sales, and a 10% withholding tax on dividends paid to local and foreign shareholders. Clarifications have provided some exemptions to the capital gains tax and guidance on calculating dividend withholding taxes. These amendments and clarifications apply retroactively to transactions since September 2013.

1. Argentina Clarifies Income Tax Provisions
(Bristol, UK) - Argentina has, during the recent past, published amendments to income tax provisions.
Certain clarifications have been recently issued relating to these amendments. These clarifications
concern levy of tax on transactions related to securities, specifically share transfers and dividend
distribution, reports Nair & Co.’sInternational Tax Services Team.
Following are highlights of a few amendments that have come into force since September 2013:

Introduction of 15% income tax on the net gains from sale, exchange, barter of securities
including but not limited to shares, titles and bonds.

A tax rate of 13.5% on the gross sales price of the securities transferred by foreign beneficiaries.

A 10% withholding tax on dividends distributed by local entities to both residents and foreign
shareholders.

Equalization tax of 35% shall also be imposed in addition to withholding tax in certain cases.
Features of the recently published clarifications related to the above amendments include:

Certain exemptions from the above 15% or 13.5% tax on the sale, exchange or barter of
securities.

Clarification on the method of calculating the gains from securities, in certain circumstances.

Concerning the calculation of the 10% dividend withholding tax, the equalization tax should be
applied first and then the resulting amount of the distribution would be subject to the
withholding tax.

Clarification on the applicability of the 10% dividend withholding tax:

If dividends are distributed in kind.

In certain complex scenarios like capital redemption.

2. These clarifications are applicable for the above transactions taking place on or after 23 September
2013.
Nair & Co.’s international tax team advises companies operating in Argentina to carefully analyse these
amendments to assess possible impact.
For more information about international taxation laws or to learn more about ourInternational
Expansion Services team please contact us.
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