Impuesto al Endeudamiento y Tenencia de Obligaciones Negociables

The paper analyzes the withholding tax rates applicable to interest paid abroad under the 22 double taxation treaties currently in force in Argentina. It reviews the general caps on withholding, the cases of zero-rate withholding for preferential or development loans, the application of grossing up, the comparison with development loans under the Income Tax Law, and the impact of the Most Favored Nation clause.

The paper analyzes the Argentine Supreme Court case "Telecom" in which the Court determines that expenses related to the purchase of shares are deductible from the Argentine Income Tax

The paper analizes the Argentine Supreme Court case between the Federal Tax Authorities and the Province of San Luis (Argentina). The Federal Tax Authorties challenge a Decree of the Governor of San Luis in which the Governor acted as the application authority of a federal tax law. The Argentine Supreme Court is the competent to decide any legal discussion between the Federal Government and the Provinces, and decided in favor of the Tax Authorities.