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ILN Today Post

Argentina – Client Alert – Tax Reform

The Argentine Congress approved a comprehensive tax reform in Argentina, effective in general January 1st, 2018. This summary describes some of the main changes:

A. Corporate income tax rate and dividend withholding tax

The corporate income tax rate is decreased from 35% to 30% for fiscal years starting 1 January 2018 to 31 December 2019, and to 25% for fiscal years starting 1 January 2020, and onwards. Dividend withholding tax rates of 7% for profits accrued during fiscal years starting 1 January 2018 to 31 December 2019, and 13% for profits accrued in fiscal years starting 1 January 2020 and onwards. The new withholding rates would apply to distributions made to shareholders qualifying as resident individuals or nonresidents. Additionally, the reform repeals the 35% “equalization tax” as from 1 January 2018.

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ILN Today Post

Public Registry of Commerce approves Simplified Corporation regulation

Today, the Public Registry of Commerce (Inspección General de Justicia”) has approved the regulation of theSimplified Corporation (Sociedad Anónima Simplificada or “SAS”), which will enable the incorporation of this type of companies as from September 1. The main features of the SAS are the following:

 The SAS may be incorporated by one shareholder and the formalities of incorporation have been relaxed substantially.

 The incorporation may be completed within 24 hours.

 The initial minimum corporate capital is very low (approx. USD 1,000).

 Simplified valuation procedure of capital contributions in kind (e.g. trademarks, software, etc.).

 More flexibility to create different stock classes and special rights.

 Flexibility to design the management structure.

 Only one director must be an Argentine resident.

 Simplified accounting and corporate records.

 National Tax ID may be procured within 24 hours.

 Reduced timing for opening a bank account.

Please let us know should you need further information.

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ILN Today Post

Salaberren & Lopez Sanson (SyLS) in M&A Deal of the Year Award by Latin Lawyer

SyLS advised on the transaction that won the M&A Deal of the Year Award by Latin Lawyer, as co-counsel to Papa Energia S.A. in its approx. US $1 billion acquisition of Petrobras Argentina S.A.

SyLS Team was led by Rafael Salaberren Dupont (Head of the Corporate – Finance and M&A Practice), Senior Associates Juan Manual Campos Alvarez and Mariano Monserrat and Associate Diego D’Odorico.

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ILN Today Post

Argentina Ministry of Economy issues resolution repealing foreign exchange requirement

On May 5th, 2017, the Argentina Ministry of Economy issued a resolution repealing a foreign exchange requirement regarding loans between Argentine residents and foreign residents. Loans made by foreign residents to Argentine residents could only be repaid after a 120-day period had elapsed since the conversion into pesos of the proceeds of the loan. This 120-day waiting period has been repealed today, meaning that amortization schedules of loans can be agreed upon between the parties freely.

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ILN Today Post

Argentina and Mexico enter into a Double Taxation Treaty (DTT)

Argentina and Mexico have entered into a Double Taxation Treaty (DTT). Entry into force is yet pending. We estimate that the provisions of the agreement shall have effect as from fiscal year beginning on January 1st, 2018.

Some relevant provisions applicable to intercompany transactions are as follows:

1) Interests: Withholding tax may not exceed 12% (reduced from 35% Argentine withholding tax rate).

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