Argentina and Spain signed a new double tax treaty on March 11, 2013. The Argentine government terminated the previous treaty in 2012. We expect the treaty to be ratified soon and it will apply retroactively to January 1, 2013.
This is an important development for US MNCs who have relied on the Spanish treaty with Argentina to facilitate more efficient holding company structures for their Latin American affiliates, including Argentina. The treaty can help mitigate Argentine withholding tax on dividend distributions in certain cases, as well as withholding tax on interest, royalties and certain service payments.