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HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual: Guidance by country: Argentina: Tax spared

The agreement provides for credit to be given for tax ‘spared’ (see INTM161270-161290) in Argentina under the provisions of Argentinian law expressly set out in Article 23(4).

Relief from United Kingdom tax under this provision is not available where the profits, income or chargeable gains on which tax is spared arise or accrue after 1 August 2007; or if the income or profits from the source in question arise in a period beginning more than ten years after tax was first ‘spared’ in respect of that source (whether that period began before or after the agreement entered into force).

All amounts of tax spared for which credit relief is given should be reported to HMRC Tax Treaty Team as mentioned in INTM161290.