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5.6. Qualification of Specific Income Categories for Tax Purposes

Income from stock and securities issued by Argentine entities is deemed Argentine-source income. For treaty purposes they are qualified as “dividends” and “interest”, respectively.

Income from personal property situated or economically utilized in the country as well as rights placed or economically used in the country, is deemed Argentine-source income. These items of income are generally included in the royalty clause (Article 12) of the Argentine treaties.  

Fees or other compensation paid for technical, financial or similar advice rendered from abroad is deemed to be Argentine-source income. Note that, with the exception of the treaties with Germany, France and Italy, all Argentine treaties include technical assistance services under the royalty clause (Article 12) and allow the application of withholding at source.

Interest Income

Interest includes remuneration paid for credits, loans or placements of funds of any origin or nature, obtained from the non-resident. It also includes foreign exchange losses on foreign loans.

Royalty Income

Royalty includes any consideration received, in money or kind, for the transfer of ownership, use or enjoyment or for the transfer of rights, the amount of which is determined in relation to a unit of production, sale, exploitation etc.

Service Fees

Service fee includes consideration for services of technical assistance, engineering or consultancy under a registered contract and fulfils requirements laid down by Law of Technology Transfer.