Argentina

Corporate residence is determined on the basis of centres of activity, which may be the location of a company’s economic activity or management activity.

Permanent establishment (PE)

Centres of activity in Argentina of non-Argentine corporations are treated as PEs.

As part of the 2017 tax reform, a PE definition has been introduced into the Income Tax Law. Such a definition is generally aligned to the one included in the Organisation for Economic Co-operation and Development's (OECD's) Model Tax Convention for the Avoidance of Double Taxation, although it is broader as it includes the performance of services by a non-resident provider, including services rendered by consultants, within the National Territory for a total length greater than six months within any 12-month period.