In order to strengthen trade relations with Switzerland, Argentina signs a Double Taxation Avoidance Agreement on Income and Wealth Taxes.
Said instrument was already approved by Law No. 27,010, published on December 11, 2014, revealing the expeditious treatment with which the agreement was treated by the National Congress, with a view to strengthening trade relations between both nations. The referred agreement enters into force on November 27.
This agreement contemplates, among other things, the power for Argentina to apply withholding taxes on royalty payments to Swiss companies and allows the taxation of shares and equity interests with property taxes.
On the other hand, it eliminates the most favored nation clause, which compromised the treatment that could be agreed with third countries in future tax treaty negotiations, and establishes a general anti-abuse clause, so that residents of third countries do not take undue advantage of the benefits of the Convention by structuring abusive tax planning that results in double non-taxation.
It also enables the exchange of tax information at the request of the tax administrations, with the incorporation of a minute with the commitment to implement the automatic exchange when it is defined as an international standard. This will allow the AFIP to obtain information on the financial investments of Argentines in Switzerland and on the foreign trade operations of Argentine exporters that use Swiss companies as intermediaries or commercial traders.
http://www.afip.gov.ar/institucional/Documentos/acuerdos/SUIZA.pdf
https://www.news.admin.ch/message/index.html?lang=en&msg-id=59271
