1. Background
1.1 An overview of current tax proposals
The Omnibus Bill (Ley de Bases y Puntos de Partida para la Libertad de los Argentinos, the Bill) is a multi-purpose, comprehensive legislative…
Main features of the new extraordinary prepayment on account of Income Tax
General Resolution 5248/22 (the Resolution), issued by the Argentine Tax Agency (AFIP), and gazetted on August 16, 2022…
Notes on the starting of MLI internalization process
Background
The Multilateral Convention to Implement Tax treaty Related measures to prevent BEPS (the Multilateral BEPS Convention or MLI) [i]…
Abridged comments for a regional appraisal and possible outcomes to implementation
2010-2020: A Decade of Profound Changes in International Taxation
Following the world financial crisis, the…
Apropos Molinos Rio de la Plata SA
1. Background: Memorandum DNI 799/10
In Memorandum 799/10, the Argentine Competent Authority (Argentine Tax Directorate, Dirección Nacional de Impuestos or DNI)…
As the Blueprint on Pillar I illustrates, the political and technical complexities inherent to the solution sought by OECD are of such magnitude, that such a sole fact opens the window to an…
A couple of days ago, in the last weekly session of the Indiana-Leeds Summer Tax Workshop, I attended the presentation of a fascinating paper by Steven A. Dean (A Constitutional Moment in Cross…
The OECD’s BEPS 2.0 project is currently navigating turbulent waters partly because of the unexpected Covid19 crisis and its impact on state budgets and the need for additional revenues, and partly…
A. Where are we? A worldwide and LATAM picture
A current worldwide picture of unilateral initiatives developed on the direct taxation of the digitalized economy includes at least the following paths:…
