SolvedDT2502 | Double Taxation Relief Manual: Argentina: Treaty summary
From HM Revenue & Customs · Double Taxation Relief Manual
The table summarises the provisions of the treaty as they relate to income beneficially owned by UK residents. The rate shown is the ‘treaty rate’ and does not reflect taxes chargeable under domestic law before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which Argentina is permitted to tax income in the relevant categories under the treaty. Rates chargeable under domestic law may be higher or lower.
In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details. The text of the treaty can be found on gov.uk.
| Subject | Comments | Article |
|---|---|---|
| Portfolio dividends | 15% | 10 |
| Dividends on direct investments | 10% | 10 |
| Conditions for lower rate on dividends on direct investments | The beneficial owner is a company which controls, directly or indirectly, at least 25% of the voting power in the company paying the dividends | 10 |
| Property income dividends | 15% | 10 |
| Interest | 12% (Note 1) | 11 |
| Royalties | 3/5/10/15% (Note 2) | 12 |
| Government pensions | Taxable only in the UK | 18 |
| Other pensions | Taxable only in the UK | 18 |
| Arbitration | No | N/A |
Note 1: Interest paid in the following circumstances is taxable only in the UK if:
the payer of the interest is the Republic of Argentina, a political subdivision, a local authority or statutory body of Argentina
it is paid in respect of a loan made, guaranteed or insured, or any other debt-claim or credit created, guaranteed or insured by the UK, a political subdivision, a local authority or statutory body of the UK
it is beneficially owned by a resident of the UK and is paid in respect of a loan granted by a bank to an unrelated party at preferential rates and which is repayable over a period of not less than five years
it is beneficially owned by a resident of the UK and is paid with respect to indebtedness arising as a consequence of:
the sale on credit by a resident of the UK of industrial, commercial or scientific equipment, provided that neither the sale nor the indebtedness was between related persons
the purchase of industrial, commercial or scientific equipment financed through a leasing contract, provided that the conditions in that contract are in accordance with the rules established by the internal tax law in force in the state in which the purchaser is resident
Note 2: The following rates apply where the gross amount is paid for the use of, or the right to use:
news (3%)
copyright of literary, dramatic, musical or other artistic work (but not including royalties in respect of motion picture films and works on film or videotape or other means of reproduction for use in connection with television) (5%)
any patent, trademark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial or scientific equipment, or for information concerning industrial or scientific experience, or the rendering of technical assistance (10%). In the case of technical assistance, the tax payable is determined after the deduction of expenses directly related to the provision of that assistance
15% of the gross amount of the royalties in all other cases