vielleicht hilft ihnen DIESES da:


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In March 1998, Argentina's executive signed a tax reform proposal containing several provisions. Among the most relevant provisions included in the tax legislation based on the bill approved by the Lower Chamber, are those related to worldwide income and the definition of residence.

In 1992, the Income Tax Law was amended, establishing that residents are assessable on worldwide income, and non residents on income of Argentine source. However, the application of this provision had not been regulated before this new tax reform. The tax consequences of these rules have been analyzed with respect to Argentine nationals assigned to work in a foreign country, or foreign individuals assigned to work in Argentina.

Residents

The following individuals will be deemed to be resident:

* Argentine nationals, except those that have lost their resident status; and
* foreign nationals who either acquire a permanent residence in Argentina, or are temporarily resident and stay in Argentina for more than 12 months.

The tax should be calculated by applying progressive rates ranging from 6% to 35% in accordance with the tax reform.

Tax filings

To report income of foreign source, in addition to Argentine source income, resident individuals – Argentine or foreign nationals – would have to file an annual tax return to determine their total tax liability.

If they are included on a local payroll, the local employer will withhold the corresponding income tax from the Argentine source income on an actual basis.

Tax credit

Residents are allowed to take as a credit the tax paid abroad on foreign source income. For this purpose, the foreign tax should be related to foreign source income reported in the respective tax return, and should have been paid before the due date for filing the Argentine tax return. In addition, a supporting payment slip would be required.

End of assignment

In general, Argentine nationals returning to Argentina would be considered residents when the following conditions are fulfilled:

* they lost resident status when leaving Argentina;
* they acquired the resident status for tax purposes in the host country; and
* they are coming back to Argentina to remain on an habitual basis.

If the above conditions are complied with, the individual will be deemed to be a resident in accordance with the following rules:

* when he or she has a permanent home in Argentina;
* when he or she has his or her centre of vital interest in Argentina;
* depending on the term of residence in Argentina and abroad (to be regulated); or
* if the above rules could not be applied, when they are Argentine nationals.


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im übrigen figuriert argentinien definitiv nicht auf der liste der OFFSHORE-JURISDICTIONS... darum der grundsätzliche unterschied zu ländern wie belize etc.


wohl bekomm's


ffbkdavid@creatrustconsult.com

Creatrust Management AG Offshore Corporate Services