Emerging Markets Rates and Currencies Handbook

capital contribution was transferred and sold for ARS in the FX Market as from October 2, 2020 and that the repatriation occurs at least 2 years afterwards. Additional Comments Registration Requirements All inflows and outflows of foreign currency must be channeled and duly registered by financial entities through the Information Regime of Foreign Exchange Transactions (“Régimen Informativo de Operaciones Cambiarias” or “RIOC”) established by the BCRA. Citi Argentina Bartolome Mitre 502/530 Buenos Aires C1036AAJ Argentina FX Sales Contact: +5411 4329 1844 Tax Summary – Argentina Argentina W/H Tax • 35% WHT general rate • Under certain tax treaties rate is typically 10- 20% • 15.05% WHT if lender is a “Basel bank” • 35% WHT for tax haven lender • No WHT • N/A • N/A Deductibility of interests • Fully deductible if W/H tax is 35% • The deduction on interest expense and foreign exchange losses with local and foreign related parties now is limited to 30% of the taxpayer’s taxable income before interest, foreign exchange losses, and depreciation. The taxpayer is entitled to carry forward • excess non- deductible interest for five years and unutilized deduction capacity for three years. • Interest is deductible (limited to 30% of the taxable income detailed in interco debt) • Fully deductible • N/A • N/A Deductibility • Fully deductible • Hedging • N/A Country Tax Deductibility and Considerations Inter-Co Debt Offshore Derivatives Equities Bank Loans Offshore Local Borrowing