France publishes Argentina treaty amendment for 2027 application

Withholding ceilings

For dividends, the amended treaty caps source-state tax at 10% where the beneficial owner is a company that directly held at least 25% of the payer's capital throughout a 365-day period including the payment date; otherwise the ceiling is 15%. Interest is generally capped at 12%, with exclusive residence-state taxation for specified cases. Royalties are capped at 3% for international information, 5% for specified copyright payments and 10% for other royalties. The 5% copyright ceiling is limited to the author or the author's heir, while unregistered technology-transfer contracts may face a 15% ceiling.^[2]

Services and share disposals

The protocol adds a service permanent-establishment test where employees or other personnel provide services in the other state on the same or a related project for more than 183 days in total during a 12-month period beginning or ending in the relevant tax year. The source state may tax gains on shares deriving more than 50% of their value, directly or indirectly, from local immovable property during the preceding 365 days, subject to the business-property exclusion in the protocol. Other corporate-share gains are capped at 10% where the seller held at least 25% of the company's capital and 15% in other cases.^[2]

Application and review

The protocol applies to withholding taxes on amounts paid from 1 January 2027 and to other income and wealth taxes for tax years beginning from that date. A most-favoured-nation clause can extend more favourable later Argentine treaty treatment to specified income or permanent-establishment rules. Groups should identify France-Argentina payments, disposals and service projects, confirm residence and beneficial ownership, test holding periods and technology-contract registration, and track service days. The protocol does not create a separate return; domestic withholding and reporting procedures continue to govern how relief is claimed.^[1][2]