The protocol to the 1980 income tax treaty between Argentina and Brazil was signed on 21 July 2017. 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;
- Article III (General Definitions) is amended with respect to the Argentine competent authority (Ministry of Finance), a…