Argentina Publishes Synthesized Tax Treaty Text with France, MLI Effective January 1, 2026

Argentine Treasury Releases Key Tax Document

The Argentine Treasury, under the Ministry of Economy, officially published a synthesized text, in French, of the 1979 Double Taxation Agreement (DTA) and its associated protocols with France. This publication, made around December 31, 2025, integrates the provisions of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI), which became effective for Argentina on January 1, 2026.

The 1979 Double Taxation Agreement and its Evolution

The original Convention between the Government of the French Republic and the Government of the Argentine Republic for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital was signed in Buenos Aires on April 4, 1979. This foundational agreement has seen subsequent protocols, including those in 1979 and 2001. A notable amendment protocol was enacted on August 10, 2007, which entered into force on October 1, 2007, and applied from January 1, 2008, introducing changes to covered taxes and methods for eliminating double taxation.

MLI's Entry into Force and Purpose

Argentina deposited its instrument of ratification for the MLI with the Organisation for Economic Co-operation and Development (OECD) on September 29, 2025. This action solidified the MLI's entry into force for Argentina on January 1, 2026. Argentina had signed the MLI on June 7, 2017, and its approval by the Argentine Congress, through Law 27,788, was published in the Official Gazette on May 28, 2025. The MLI is a crucial international tax instrument designed to:

• Incorporate anti-abuse clauses to prevent treaty shopping.
• Redefine the concept of 'permanent establishment' to curb artificial structures.
• Improve mechanisms for resolving tax disputes between countries.

The synthesized text aims to facilitate the application of these MLI provisions to the existing DTA between Argentina and France.

Application Dates for Tax Measures

The application of the MLI's provisions varies depending on the type of tax and the jurisdiction:

• For withholding taxes, the MLI applies from January 1, 2026.
• For all other taxes in Argentina, the MLI will apply to taxable periods beginning on or after January 1, 2027.
• For all other taxes in France, the MLI will apply to taxable periods beginning on or after July 1, 2026.

This staggered approach ensures a structured transition for taxpayers and authorities in both nations.