Exception To The Tax On Minimum Presumed Income.

On May 18, 2017, the Argentine Tax Authorities ("AFIP") issued General Instruction No. 2/2017, adopting the ruling of the Argentine Supreme Court of Justice (the "Court") in the cases "Hermitage SA" (2010) and "Diario Perfil SA" (2014). In accordance with this ruling, AFIP exempts taxpayers from paying the tax on minimum presumed income when they can prove the existence of losses in their financial statements and register them in the income tax affidavit of the applicable fiscal year.

The tax on minimum presumed income is calculated by applying a rate of 1% on the value of the assets of Argentine tax residents located in Argentina or abroad.  The tax was created on the presumption that the taxpayers' assets yield profits. This presumption is calculated over the value of the taxpayer´s assets at the end of the fiscal year.