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Argentina Removes Namibia, Others Jurisdictions From “Non-Cooperative” List

By:Staff writer
Argentina’s tax administration has announced the removal of Namibia and 14 other jurisdictions from the government’s list of low- or no-tax jurisdictions for the purposes of tax implications, pursuant to Decree 48/2023, which modifies the list provided by Decree 862/2019, the Society of Trust and Estate Practitioners (STEP) has reported yesterday.
The Decree, which amends the Income Tax Act, was published in the country’s Official Gazette on January 27, 2023 and will apply to fiscal periods following that date.
The Argentinian government has removed Namibia, Botswana, Eswatini, Cape Verde, Kenya, Liberia, Mauritania, the Maldives, Bosnia and Herzegovina, Jordan, Mongolia, Montenegro, Namibia, Oman, Paraguay and Thailand.
The list of non-cooperative jurisdictions for tax purposes is used in relation to various tax rules, including CFC and transfer pricing rules.
The Decree sets out that “non-cooperative jurisdictions” are those jurisdictions that do not have an agreement in place with Argentina to exchange information on tax matters or to avoid international double taxation with a broad information exchange clause.
“The agreements and conventions…must comply with the international standards of transparency and exchange of information in tax matters to which the Argentine Republic has committed,” it states.
Some of the jurisdictions removed from the list have committed to the OECD multilateral Convention on Mutual Administrative Assistance in Tax Matters. AFIP confirms that all agreements in place must comply with the international standards of transparency and exchange of information. Countries that have such agreements but do not adequately comply will be considered non-cooperative.
AFIP further notes that there will now be a lower transfer pricing administrative burden for taxpayers carrying out operations with the jurisdictions removed from the list.
Eighty jurisdictions remain on the current list of non-cooperative jurisdictions, including several in Latin America: Bolivia, Guyana, Honduras, Nicaragua and Suriname.
On 9 December 2019, the Argentine Government published in the Official Gazette Regulatory Decree 862/2019, which established a new Regulatory Decree for the Income Tax Law. Article 24 of the Regulatory Decree included a list of 95 jurisdictions considered to be non-cooperating jurisdictions for income tax purposes for fiscal years closed after 9 December 2019.

Staff Writer

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