Through Law 24,850, published in the Official Gazette of 22 June 1997, the Congress of Argentina ratified the double taxation treaty and protocol with Belgium, signed on 12 June 1996. The treaty was concluded in the Spanish, French, Dutch and English languages; the English text prevails in case of divergence. The treaty generally follows the OECD Model and will be applicable, in general, as from 1 January of the year following that in which the treaty enters into force.
Under the treaty, the maximum withholding tax rates are:
- 15% on dividends in general, but 10% if the recipient is a company holding 25% of the paying company;
- 12% on interest, with an exemption for interest on loans for financing machinery or equipment purchases from unrelated companies, on loans for promoting machinery exports, on certain preferential loans paid to a bank and on the usual loans to public bodies; and
