Tax Transparency? It Depends on who you Ask. Argentina and the WTO

By Robert Robillard - 2 octobre 2015

This blogpost originally appeared on

What the BEPS?

The OECD has been pushing really hard on tax transparency. BEPS Actions #5, #11, #12, and #15 are centered on tax transparency measures.

The EU recently released its Tax transparency package.

Most CFC regimes across the globe include some form of tax transparency provisions to grant access to specific tax benefits.

Then came along the World Trade Organization (WTO)’s proverbial wrench…

In a somehow surprising decision, the WTO indicated:

« This dispute concerns eight financial, taxation, foreign exchange and registration measures imposed by Argentina mostly on services and service suppliers from jurisdictions that do not exchange information with Argentina for the purposes of fiscal transparency (“non-cooperative jurisdictions”).

The measures at issue in this dispute are the following:

  • Withholding tax on payments of interest or remuneration (measure 1);
  • Presumption of unjustified increase in wealth (measure 2);
  • Transaction valuation based on transfer prices (measure 3);
  • Payment received rule for the allocation of expenditure (measure 4);
  • Requirements relating to reinsurance services (measure 5);
  • Requirements for access to the Argentine capital market (measure 6);
  • Requirements for the registration of branches (measure 7); and,
  • Foreign exchange authorization requirement (measure 8). »

According to the WTO, these measures contravene with specific provisions of the General Agreement on Trade in Services.

What the BEPS?

Robert Robillard, Ph.D., CPA, CGA, Adm.A., MBA, M.Sc. Econ., M.A.P.
Senior Partner, RBRT Inc.
514-742-8086; robertrobillard « at »

The convergence of RBRT’s tax, accounting and economics expertise makes a difference. The information in this blog post is general information only. Data and information come from sources believed to be reliable but complete accuracy cannot be guaranteed. RBRT Inc. or the author are not responsible or liable for any error, omission or inaccuracy in such information. The opinions expressed in this blogpost are those of the author. Readers should seek advice and counsel from RBRT Inc. as required.