In response to a question from the private sector, the tax administration of Argentina (AFIP) has given its position with respect to the application of the transport tax treaty between Argentina and Spain, signed in 1978. The authority's position is that the treaty is not in force (Alcance 13288-2013-2012/2 of 15 May 2013 of the Subdir. Gral de Coordinación Técnico Institucional of AFIP – recently available).
AFIP considers that the transport tax treaty was repealed when the comprehensive bilateral tax treaty between Argentina and Spain, signed in 1992, entered into force; and that the termination of the comprehensive tax treaty does not give effect to the repealed transport tax treaty.
The transport tax treaty between Argentina and Spain, signed in 1978 (Law 22,571), was repealed by application of provision 7 of the protocol to the tax treaty signed in 1992 and in force as of 28 July 1994 (Law 24,258).
Note. Argentina and Spain signed a new tax treaty on 11 March 2013.
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