The pending protocol to the 1980 income (and capital) tax treaty between Argentina and Brazil will enter into force on 29 July 2018. The protocol is the first to amend the treaty and includes several changes resulting from the BEPS project. Some of the main changes include:
- The title and preamble of the treaty are updated, including new language regarding treaty abuse developed as part of the BEPS project, as well as an expansion of the scope of the treaty to cover capital taxes;
- Article II …