Supreme Court decision on calculation of withholding tax

On March 5 2013, the Supreme Court gave its decision in Ciccone Calcográfica S.A., specifically, on the circumstances under which a gross-up of the taxable base of the withholding tax proceeds. Details of the case are summarized below.

(a) Facts. Ciccone, an Argentine resident company, which business is the print of paper money, entered into an agreement with the National Bank of Angola to print "kwanzas" bills. Two additional non-resident companies, Jit Commerce Corporation and Business Stra…