Argentina put an end to the provisional application of the Treaty with Switzerland for the Avoidance of Double Taxation signed in 1997.
In 1997, the Argentine and the Swiss Government signed a Treaty for the Avoidance of Double Taxation regarding Income Tax and Assets Tax. The Treaty has never been ratified by the countries, but it was provisionally enforced as from January 1, 2001 by means of an agreement executed by the countries' Financial Ministers.
The Treaty provided significant advantages for taxpayers and companies affected by it, particularly on Income Tax withholdings concerning payments of interests and royalties, and regarding Personal Assets Tax applicable to Argentine companies' shares held by shareholders domiciled in Switzerland.
On January 31, 2012, through a notice published in the Official Gazette, the Argentine Government issued a resolution ending the Treaty's provisional application and notified this resolution to the Swiss Government through a letter issued on January 16, 2012. In the mentioned letter, the Argentine Minister of Foreign Affairs also informed the Swiss Government about its decision not to ratify the Treaty.
The Argentine Government informed the Swiss Government that the Treaty executed between both countries to avoid double taxation regarding benefits derived from air and shipping transport "will continue to be suspended".
Finally, the Argentine Government proposed that the Swiss Government initiate a negotiation process, aiming to celebrate an information exchange agreement on tax and customs aspects, following both the Organization for Economic Cooperation and Development and the Worldwide Customs Organization guidelines. This proposal was made "in order to strengthen the relationship between both countries on international customs and tax transparency".
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.