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HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual: Guidance by country: Argentina: Dividends

The Argentinian tax deducted from dividends at the agreement rate of 15 per cent (10 per cent if the beneficial owner is a United Kingdom company which controls, directly or indirectly, at least 25 per cent of the voting power in the company paying the dividend) qualifies for credit as a direct tax (see INTM164010(c)). The reduced rate does not apply if the dividends are effectively connected (see INTM153110 fifth sub-paragraph) with a business carried on through a permanent establishment or fixed base which the recipient has in Argentina.

A United Kingdom company controlling, directly or indirectly, at least 10 per cent of the voting power of the Argentinian company paying the dividend is entitled, under Article 23(1)(b), to credit for underlying tax (see INTM164010(d)).