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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Double Taxation Relief Manual: Guidance by country: Argentina: Capital gains

Gains arising to a resident of the United Kingdom from the disposal of property situated in Argentina may be taxed in Argentina as well as in the United Kingdom (except that Argentina may not tax a gain from the disposal of movable property which a United Kingdom enterprise has in Argentina for the purpose of its business activities if the business profits derived by the enterprise are taxable only in the United Kingdom in accordance with the business profits Article of the agreement).

However, where the gain is derived from the disposal of shares it is taxable in Argentina at a rate not exceeding 15 per cent (10 per cent where the person realising the gain controlled immediately before the disposal, directly or indirectly, at least 25 per cent of the voting power in the company in respect of which the share disposal was made) (Article 13(6)). This reduction in rate does not apply where the shares disposed of derived their value or the greater part of their value directly or indirectly from immovable property situated in Argentina, unless they are quoted on an approved Stock Exchange (Article 13(2)).