June 28, 2019
Ministry of Finance
Tax Convention with Argentina was Signed
[Provisional translation]1. On June 27 (Thursday), the Government of Japan and the Government of the Argentine Republic signed the Convention between Japan and the Argentine Republic for the Elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance in Osaka. This Convention is the first tax convention to be concluded between Japan and the Argentine Republic in light of an increasingly close economic relationship between the two countries.
2. For the purpose of eliminating double taxation arising between the two countries, this Convention clarifies the scope of taxable income in the two countries. In addition, this Convention will enable the tax authorities of the two countries to consult each other on taxation not in accordance with the provisions of this Convention, to exchange information concerning tax matters and to mutually lend assistance in the collection of tax claims. It is expected that, while eliminating double taxation and preventing international tax evasion and tax avoidance, this Convention promotes further mutual investments and economic exchanges between the two countries.
【Reference 1】 Next Steps
After the approval in accordance with the domestic procedures of the two countries (in the case of Japan, approval by the Diet is necessary), this Convention will enter into force on the thirtieth day after the date of exchange of diplomatic notes indicating such approval and will have effect:
(a) with respect to taxes levied on the basis of a taxable year, for taxes for any taxable years beginning on or after
January 1 in the calendar year next following that in which this Convention enters into force; and
(b) with respect to taxes levied not on the basis of a taxable year, for taxes levied on or after January 1 in the
calendar year next following that in which this Convention enters into force.
The provisions concerning the exchange of information and the assistance in the collection of taxes will have effect from the following dates without regard to the date on which the taxes are levied or the taxable year to which the taxes relate:
(a) with respect to the provisions of the exchange of information, the date of entry into force of this Convention; and
(b) with respect to the provisions of the assistance in the collection of taxes, the date to be agreed between the
Governments of the two countries through an exchange of diplomatic notes.
【Reference 2】 Termination of the Exchanged Notes concerning Mutual Tax Exemption for Income from the International Transportation Business
As taxes on income from the international transportation business will be exempted in the source country under this Convention, the arrangement between the Government of Japan and the Government of the Argentine Republic constituted by the Notes exchanged at Buenos Aires on 29 December 1975 concerning the avoidance of double taxation on income derived from the operation of ships or aircraft in international traffic will, pursuant to this Convention, terminate and cease to have effect with respect to taxes to which this Convention shall have effect.
【Reference 3】 Texts and Key Points of the Convention
・“Convention between Japan and the Argentine Republic for the Elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance”（Japanese(PDF:246KB)・English(PDF:83KB)）
・Key Points of Tax Convention with Argentina