Argentina: Senate approves MLI to prevent base erosion and profit shifting (BEPS)

Seeks to reduce tax avoidance strategies that exploit gaps and mismatches in tax rules

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May 13, 2025

The Argentine Senate on May 7, 2025, approved the Multilateral Instrument (MLI) - Multilateral Tax Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS). The law is expected to be published in the official gazette soon and will take effect after its promulgation by the executive branch and subsequent deposit with the Organisation for Economic Cooperation and Development (OECD).

The MLI's implementation will affect the analysis of multinational enterprises' structures or transactions involving double taxation treaties. Key aspects include the principal purpose test (PPT) and the concept of permanent establishment (PE). The adoption of the MLI seeks to strengthen the international tax system's integrity by reducing tax avoidance strategies that exploit gaps and mismatches in tax rules.


For more information, contact a KPMG tax professional in Argentina:

Agostina Bermudez | agostinabeatrizbermu@kpmg.com.ar

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