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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
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Double Taxation Relief Manual: Guidance by country: Argentina: Interest

Interest arising in Argentina and paid to a resident of the United Kingdom who is the beneficial owner of the interest is taxable in Argentina at a rate not exceeding 12 per cent (Article 11(2).

Interest arising in Argentina and paid to a United Kingdom resident is, however, exempt from Argentinian tax if:

  • the payer is the Argentinian State or a political subdivision, local authority or statutory body thereof (Article 11(3)(a) or
  • the interest is paid in respect of a loan or any other debt-claim or credit made, created, guaranteed or insured by the United Kingdom or a political subdivision, local authority or statutory body thereof (Article 11(3)(b) or
  • the interest is beneficially owned by a United Kingdom resident and is paid in respect of a loan granted by a bank to an unrelated party at preferential rates where the loan is repayable over a period of not less than five years (Article 11(3)(c) or
  • the interest is beneficially owned by a United Kingdom resident and is paid in respect to indebtedness arising as a consequence of the sale on credit between unrelated persons, or the purchase through a leasing contract, of industrial, commercial or scientific equipment (Article 11(3)(d).

Where, however, the interest is effectively connected with a permanent establishment or fixed base which the United Kingdom resident recipient has in Argentina, the provisions of the Business Profits Article (Article 7) or the Independent Personal Services Article (Article 14) will apply.