Andrés Edelstein Ignacio Rodríguez According to domestic regulations, in order to enjoy a favourable treatment granted by tax treaty provisions, foreign beneficiaries are required to fulfill certain formalities. In this regard, they are obliged to provide the Argentine entity appointed as withholding agent with an affidavit indicating the applicable section of the relevant treaty and stating that: i) the nonresident recipient is a resident in the other contracting state, ii) it is the beneficial owner of the income, and iii) does not have a permanent establishment in Argentina.
April 30 2007