On 28 May 2018, the State Secretariat for International Financial Matters (SIF) published a Memorandum of Understanding (MOU) on the Agreement between the Swiss Confederation and the Republic of Argentina for the Avoidance of Double Taxation in the Area of Taxes on Income and Capital of 20 March 2014 (DTA Switzerland-Argentina).
The agreement refers to the difficulties and uncertainties which arose in connection with the issue of the Swiss forms in relation to Article 10, para. 2 (dividends) and Article 11, para. 2 (interest) of the DTA Switzerland-Argentina.
The agreement regulates in detail how Argentina should issue the Argentinean residence certificates in this context. This confirmation should state at what time or period the taxpayer was fiscally resident in Argentina and when the confirmation was issued.
The agreement should be applicable to all pending and future applications. Applications that have already been rejected due to the lack of a confirmation of tax residence on the Swiss form should be reviewed again on condition that a new application is submitted. The limitation period should be calculated on the basis of the first request.
