Does Argentina have a tax treaty with the US, the UK or Spain?

Last verified: 27 Oct 2026 · Status: Changing

Short answer. Argentina has income tax treaties in force with the UK (in force 1 August 1997) and Spain (in force 23 December 2013), but not with the United States. Both treaties cap Argentine withholding at 10% or 15% on dividends, 12% on interest and 3% to 15% on royalties. US recipients pay full domestic rates.

As of 26 Oct 2026. Rules in force at that date.

Key rules

The official list. The Ministry of Economy's list of double tax conventions in force (checked 26 Oct 2026) names 24 partners: Australia, Austria, Belgium, Bolivia, Brazil, Canada, Chile, China, Denmark, Finland, France, Germany, Italy, Mexico, the Netherlands, Norway, Qatar, Russia, Spain, Sweden, Switzerland, Turkey, the United Arab Emirates and the United Kingdom. The United States is not on it. Luxembourg (signed 13 April 2019) and the Czech Republic (signed 14 April 2026) are signed but awaiting approval by Congress.

United States: no income tax treaty. The only US tax agreement on the Ministry pages is a shipping and air transport agreement (signed 20 July 1950, amended 30 December 1987, approved by Law 24.399, BO 13 December 1994). On information, the Ministry of Economy reported that an information exchange agreement was signed in December 2016 and an automatic exchange (FATCA) agreement on 5 December 2022, with the first exchange in September 2024. We did not find their texts on an official Argentine site (unconfirmed). Neither reduces withholding tax.

United Kingdom. Convention signed 3 January 1996, approved by Law 24.727 (BO 4 December 1996), in force 1 August 1997 (Ministry list). Caps: dividends 10% if the beneficial owner is a company controlling at least 25% of the voting power, 15% otherwise (art. 10(2)); interest 12% (art. 11(2)), with exemptions in art. 11(3); royalties 3% news, 5% copyright (films excluded), 10% patents, trademarks, know how, equipment and technical assistance, 15% other (art. 12(2)).

Spain. Convention signed 11 March 2013, approved by Law 26.918 (BO 18 December 2013), in force 23 December 2013 (Infoleg record; Ministry list). Caps: dividends 10% if the beneficial owner is a company (not a partnership) holding directly at least 25% of the capital, 15% otherwise (art. 10(2)); interest 12% (art. 11(2)), with exemptions in art. 11(3); royalties 3% news, 5% copyright, 10% patents, software, equipment, know how and technical assistance, 15% other (art. 12(2)).

Domestic baseline. Dividends paid abroad bear a final 7% withholding (Income Tax Law, t.o. 2019, art. 97, last paragraph). Dividends that exceed accumulated taxable income also bear a 35% "equalisation" withholding on the excess (art. 74).

Claiming the treaty rate. Before the payment, the foreign parent gives the Argentine payer a tax residence certificate from its own tax authority (valid 12 months if undated, apostilled unless verifiable online) and the affidavit in the Annex to ARCA RG 5855/2026 (arts. 2 to 4). Without the certificate, the payer withholds at the full domestic rate (art. 7). Infoleg lists no amendments to RG 5855 as of 26 Oct 2026.

What changes the answer

Interest and royalties. Here treaties matter. A US lender's intragroup interest bears 35% (ITL art. 104(c)(2)); a UK or Spanish lender's is capped at 12%. A US licensor of a registered patent bears 28% (art. 104(a)(2)) against 10% for UK or Spain.
Holding test. UK uses 25% of voting power; Spain 25% of capital, held directly, and excludes partnerships.
Registration. Both protocols cap royalties only if Argentine registration requirements are met (UK Protocol para. 4(a); Spain Protocol para. 4(a)).
MLI and MFN. The Ministry list shows MLI synthesised texts for both treaties, which may add anti abuse tests (unconfirmed). The UK Protocol para. 6 extends lower rates later granted to an OECD member automatically; no official guidance on its effects was found (unconfirmed).

Worked examples

An Argentine SA pays a dividend of US$100,000 to its 100% parent. Pesos at dólar MEP ARS 1,563.90 per US$ on 23 Oct 2026, a rate (dólar MEP selling rate (dolarapi.com)). The real conversion follows RG 739, art. 3.

Step or item	Time	Cost ARS	Cost USD
Gross dividend	Payment date	156,390,000	100,000
Domestic 7% (ITL art. 97), any parent	Withheld at payment	10,947,300	7,000
UK treaty cap, 10% (art. 10(2)(a))		15,639,000	10,000
Spain treaty cap, 10% (art. 10(2)(a))		15,639,000	10,000
US parent, no treaty		10,947,300	7,000
Net cash to each parent		145,442,700	93,000

ARS 156,390,000 × 7% = ARS 10,947,300 for all three parents.
UK and Spain caps: 10% × ARS 156,390,000 = ARS 15,639,000. A treaty only caps, so the 7% applies.
US parent: 7%. For an ordinary dividend, the treaty changes nothing.
Variant: if US$20,000 (ARS 31,278,000) exceeds accumulated taxable income, art. 74 adds 35% = ARS 10,947,300 (US$7,000). Total ARS 21,894,600 (US$14,000), or 14% of the gross dividend. Neither the UK nor the Spain protocol excludes the art. 74 tax from the cap (the Switzerland protocol does), so a UK or Spanish parent could argue the total is limited to 10% (ARS 15,639,000). We found no ARCA ruling either way (unconfirmed). How the 7% and the 35% combine on the same excess is also unsettled (unconfirmed).

Cost to do it: 7% of the dividend. No Argentine filing fee for the parent; the foreign residence certificate and apostille fees are set abroad (unconfirmed). Documents must arrive before the payment date.

Practical traps

Late certificate. Without the certificate before payment, the full domestic rate applies and only a refund route remains (RG 5855, arts. 7 and 8).
Assuming a US treaty. Information exchange and FATCA agreements are not tax treaties.
Technical assistance. UK and Spain treat it as a royalty taxable at 10% in Argentina, after deducting related costs (UK Protocol para. 4(c); Spain Protocol para. 4(c)).

FAQ

Is there a treaty with Ireland, Japan or Luxembourg? None is on the in force list. Luxembourg is signed but not approved; Japan has only a shipping and aircraft agreement (Law 21.386).

Does the Spain treaty cover personal assets tax? Yes, it lists it as a covered tax, but it still lets Argentina tax shares of Argentine companies (art. 22(4)), so the company pays 0.50% of equity.

How does a US parent avoid double tax? Only through US foreign tax credit rules, outside the scope of Argentine sources (unconfirmed).

Can an Argentine company prove residence to the UK or Spain? Yes. ARCA issues residence certificates online, usually within 72 business hours (RG 5572/2024, art. 7).

Published 27 Oct 2026 from our research draft. Points marked (unconfirmed) have not yet been checked against the official text; rely on the primary sources linked below.