Denmark and Argentina signed a double tax treaty on 12 December 1995. The treaty has entered into force. Highlights of the treaty are as follows:
- The maximum tax in the country of source on dividends paid to a resident of the other country is 10% if the recipient is a company that directly holds at least 25% of the capital of the paying company and 15% in other cases.
- The maximum tax in the country of source on interest paid to a resident of the other country is 12%.
- Tax in the country of source on royalties paid to a resident of the other country is 3%, 5%, 10%, or 15%, depending on the category of royalty.
- Denmark grants a matching credit for certain profits of a permanent establishment in Argentina and provides for an exemption from tax for certain dividends for ten years from the date the treaty becomes effective.
- The definition of a permanent establishment includes the provision of services when such activities continue for more than six months in a twelve-month period.
- The treaty allows a branch profits tax of up to 10% to be charged.
- Capital gains on the disposal of shares may be taxed at a rate of up to 15% in the source country.
- A most-favored-nation clause is included for the benefit of Denmark with respect to withholding tax and branch profits tax if, after 25 March 1994, Argentina concludes a more favorable treaty with any other member state in the Organization for Economic Cooperation and Development.
- The treaty includes special provisions relating to activities in connection with offshore mineral exploitation
This information was correct as of 1 April 1997
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
For further information contact Manuel G Diskenstien, Deloitte & Touche, Buenos Aires, Argentina on Tel: +54 1 326 4046, Fax: +54 1 326 7340